PRIVACY POLICY – PERSONAL DATA

As part of its online service for the Universal Registration Document – Digital URD – the Labrador Group (hereinafter "Labrador") is required to process your data. This applies when you access the Service, consult the Universal Registration Document, create an Account or when you fill out a form to obtain the document in hard copy or to contact us: you send us certain information, some of which might enable you to be identified (hereinafter "Personal Data").

Labrador respects your privacy and is committed to protecting your Personal Data. The purpose of this Privacy Policy is to inform you of the way in which your Personal Data is processed, its possible transfer to third parties as well as your rights and the options available to you to control your Personal Data and protect your privacy.

We invite you to read this Privacy Policy carefully.

1. What is Personal Data?

Personal Data means any information that may identify you directly (e.g. your first and family name or email address) or indirectly (e.g. through a unique identifier).

This means that Personal Data include information such as email addresses, mobile phone numbers, usernames, personal preferences, user-generated content, financial data and information relating to your health. Personal Data may also include unique digital identifiers such as the IP address of your computer or the MAC address of your mobile device, as well as cookies.

2. Who is responsible for processing your Personal Data?

Labrador, a simplified joint-stock company located at 8, rue Lantiez, 75017 Paris is the data controller for personal data collected via the Digital URD service, hereinafter the "Service" within the meaning of the applicable personal data regulations and in particular the EU Regulation 2016/679 on the protection of natural persons with regard to the processing of Personal Data and the free movement of such data (hereinafter "GDPR").

3. How is your Personal Data collected and for what purposes?  

For Labrador, to deliver clear, consistent and high-performance corporate information is at the heart of everything we do. We provide you with a Service accessible to all, some functionalities of which are conditional on the creation of an Account, allowing us to receive information from you and discuss with you in order to offer you appropriate content, but also to provide you with the necessary assistance when you consult certain documents. For all these reasons, there are many ways in which you can communicate your Personal Data to us, and in which we can collect them.

We may collect Personal Data from you, or receive them from you, via our Service and pages dedicated to Digital URD.

In some cases, you provide us with Personal Data directly (e.g. when you create an Account for the Service, when you wish to obtain the Universal Registration Document in hard copy or when you contact us via the relevant form).

In other cases, we collect these Personal Data indirectly (e.g., via cookies and other trackers when using the Service).

The table below provides more detailed information explaining the following:

●  In what situations can your Personal Data be provided or collected?

This column lists the activities you are engaged in, or situations in which you find yourself, when we use or collect your Personal Data. For example, if you create an Account online, when you submit comments or notes on the Universal Registration Document or when you make a contact request or if you browse one of the pages of the website.

●  What Personal Data might we obtain directly from you or by way of your interactions with us?

This column indicates what types of data about you we may collect depending on the situation.

●  How and for what purpose can we use them?

This column explains what we can do with your data, and for what purposes we collect it.

●  What is the legal basis for processing your Personal Data?

This column explains why we may use your Personal Data. Depending on the purpose for which the data are used by Labrador, the legal basis on which the processing of your data is based may be:

−   Your consent;

−   Legal obligations when the legislation in force requires the processing of data.

Overview of information about your interactions with us and its impact on your Personal Data: 

In what situations may your Personal Data be provided or collected?

What Personal Data might we obtain directly from you or by way of your interactions with us?

How and for what purpose can we use them?

 

What is the legal basis for processing your Personal Data?

 

Browsing using the Service

Data collected by cookies* during your browsing using the Service (hereinafter "Cookies").

 

For information on specific cookies placed through the Service, please consult the Cookies table at the bottom of the website. *Cookies are small text files that are stored on your device (computer, tablet or mobile) when you use the Digital URD Service.

 

-    Login data;

-    Data relating to the use of the Service;

-    Number of pages viewed by the User;

-    Names of pages viewed by the User;

-    User tracking;

-    Last site visited;

-    Duration of visit;

-    IP address (date, country, region);

-    Data relating to the browser;

-    Data relating to the device.

 

 

-    Ensure the proper functioning and security of the Service;

-    Develop statistics to analyze the use of the Service.

 

 

    

Consent

 

The validation of the Cookie banner present when accessing the Service allows the consent of the User to be obtained, with the latter being invited to refer to the section "Managing cookies".

Creating and managing an Account

Data collected when creating an Account on the Service by means of a connection

 

 

 

-    Family and first name;

-    Email address;

-    Password;

-    Username.

 

-    Allow Users of the Service to leave notes or comments in the document that are saved and accessible at any time during future visits;

-    Prepare statistics according to the location of comments or notes made by the Users. 

Consent

The validation of the information notice when creating the Account allows Labrador to obtain the consent of the User. It is confirmed by sending an automatic email with a reminder of the data processing methods and the possibility of opposing them.[2] [3] [4] 

 

User rights management (see Point 9.)

-   Family and first name;

-   Postal and/or telephone contact details;

-   Proof of identity, in case of reasonable doubt about the identity of the person concerned.

-  Enabling Labrador to respond to Users’ requests to exercise their rights.

By exercising your rights as defined in Point 9, Labrador processes your Personal Data in order to comply with its legal or regulatory obligations but also in its legitimate interests, in particular for the prevention of disputes.

The data marked with an (*) in the forms available via the Service are mandatory for the processing of the various requests made by Users. In the event that the User does not wish to communicate these data, he or she is informed that the request cannot be processed.

The User undertakes to provide only truthful, accurate, complete and up-to-date data and not to usurp those of a third party. 

4. How long does Labrador keep the data collected?

Labrador informs the User that it retains their Personal Data for a period that does not exceed that strictly necessary for the purposes for which it was processed, namely:

-   For Personal Data collected during browsing using the Service, the cookies are kept for a period not exceeding thirteen (13) months from the date of their placement on the User’s device;

-   For Personal Data collected following the creation of an online Account, they are kept for three (3) years from the date of deletion of your Account or after a period of inactivity (no login to the Account);

-   For Personal Data collected for statistical analysis purposes, the User’s IP address is kept for one year from the last login;

-   For Personal Data collected following a request to exercise rights (see Point 7), they are kept for one (1) year in the event of the exercise of the right of access or rectification from the date of receipt of the request, and three (3) years in case of exercise of the right of opposition from receipt of the request.

 

When their storage is no longer justified by legal requirements or if you have made use of a right of modification or deletion, we will delete your Personal Data in a secure manner.

 

5. Who are the recipients of the data collected?

The data collected via the Digital URD Service are intended for Labrador. They are transmitted to the company for which the Universal Registration Document is published but also to service providers and subcontractors that Labrador may call upon for the management and guarantee of the proper functioning of the proposed Service, hosting, maintenance services or technical support for our databases.

To provide the User with the most comprehensive information possible, Labrador confirms that it uses the following subcontractors:

 

Subcontractor category

 

Data transmission situation

Legal basis for data transmission

Type of data collected

Company for which the Universal Registration Document is published

When the User makes a contact request[5] [6] , the information collected via the relevant form is sent to the said Company, in accordance with its Privacy Policy, which is linked to the form, in order to:

 

- Recontact the User, in particular by email or phone calls;

- Respond to their requests for information;

- Connect the User with the appropriate department if necessary.

 

 

Consent

 

The validation of the information notice in the relevant form when sending the request allows the Company for which the Universal Registration Document is published to obtain the consent of the User. It is confirmed by sending an automatic email with a reminder of the processing methods and the possibility of opposing them.[7] 

 

For further information, please consult the Privacy Policy on the link at the bottom of the page.

 

The company collects the family name, first name, email address and telephone number of the User as well as the content of the message sent to process their request.

 

When the User makes a request for a hard copy document[8] , the information collected via the relevant form is sent to said Company, in accordance with its Privacy Policy, the link of which is attached to the form, in order to:

- Mail the requested documentation.

 

Consent

 

The validation of the information notice in the relevant form when sending the request allows the Company for which the Universal Registration Document is published to obtain the consent of the User. It is confirmed by sending an automatic email with a reminder of the data processing methods and the possibility of opposing them.

 

For further information, please consult the Privacy Policy on the link at the bottom of the page.

 

 

The company collects the family name, first name, email address and postal address of the User in order to process their request.

 

When the User has created an Account and annotated or commented on the Universal Registration Document, information relating to the location of the User’s comments or annotations is transmitted in the form of anonymous statistics to said Company, for marketing purposes.

Contract between Labrador and said Company

 

The information transmitted to the Company for which the Universal Registration Document is published are anonymized data relating to location statistics that do not allow identification of the User. This transmission is in response to a contractual obligation incumbent upon Labrador.

 

The company only collects statistics on the location of comments or annotations made in the Universal Registration Document by the User.

Digital services provider for Users of the Service [9] [10] 

 

When the User creates an online Account, the information communicated at the time of its creation is integrated into software dedicated to the management of the Users of the Service after obtaining their consent expressed during the validation of this Privacy Policy at the time of creation.

 

Consent

 

Validation of the information notice linked to the Service's Privacy Policy when creating the online Account allows Labrador to obtain the consent of the User. It is confirmed by sending an automatic email with a reminder of the data processing methods and the possibility of opposing them.[11] 

 

The service provider then has access to the data provided by the User when creating their Account, namely their family name, first name and email address as well as any information that may be related to the use of their Account.  

 

We do not offer or sell your Personal Data.

Labrador undertakes not to communicate the Data collected to a third party without obtaining the consent of the User, except in cases where a request might be made by a government authority or body, as part of the execution of legal or regulatory obligations. In any event, Labrador has ensured the commitment of its service providers and subcontractors to comply with the Regulations.[12] 

6. Where is the data hosted?

Labrador informs the User that their Personal Data is hosted by:

Cyllene

92, rue Réaumur

75002 Paris

https://www.groupe-cyllene.com/

7. Transfer of Personal Data outside the European Union

Labrador is an international group some of whose subsidiaries are located outside the European Union (hereafter "EU"). However, the data collected via the Service is not transferred outside the EU.

In the event that the Personal Data are transferred to a country located outside the EU, we undertake to inform the User in advance, unless we are exempt from doing so for a legitimate reason or in accordance with a specific legal or regulatory obligation.

In the event of a transfer of Personal Data outside the EU, we undertake to comply with the appropriate guarantees provided for by the GDPR, by implementing standard contractual clauses and by implementing the technical and organizational measures necessary to ensure the same level of protection as that required by European regulations on personal data.

8. What are Labrador's obligations?

As the data controller for the processing defined in this document, Labrador undertakes to:

-   Implement all appropriate technical and organizational measures to guarantee the confidentiality, integrity and security of the Data, including protection against loss, destruction or accidental damage;

-   Raise awareness and train internal staff in the processing of Data, the Regulations and their consequences;

-   Restrict access to User Data to only those duly authorized for this purpose;

-   Guarantee all the rights of Users under the conditions defined in Point 9.;

-   Notify the competent supervisory authority and the Users of any data breach that poses a high risk to the rights and freedoms of the Users within seventy-two (72) hours of the discovery of the fraudulent intrusion if the Regulations require it;

-   Respect the data retention periods defined in this document.

9. What are the Users’ rights over the data collected?

In accordance with the applicable Personal Data Regulations and in particular with Articles 15, 16, 17, 18, 20 and 21 of the GDPR, the User has and may exercise the following rights with respect to Labrador: 

 

YOUR RIGHTS

WHAT IT MEANS

The right to be informed

You have the right to obtain clear, transparent, understandable and easily accessible information about how we use your Personal Data and your rights. This is why we provide the information in this Policy.

 

The right to access

You have the right to access the Personal Data we hold about you (subject to certain restrictions).

 

The right to rectification

You have the right to request that your Personal Data be rectified if it is inaccurate or out of date and/or completed if it is incomplete or updated.

 

The right to erasure/right

to be forgotten

In certain cases, you have the right to obtain the erasure or deletion of your Personal Data. This is not an absolute right insofar as we may be required to keep your Personal Data for legal reasons.

 

The right to withdraw consent at any time for data processing based on consent

You can withdraw your consent to the processing of your data if this processing is based on consent. The withdrawal of this consent does not affect the lawfulness of the processing based on the consent given before the withdrawal of that consent.[13]  Please consult the table inserted in the section "What Personal Data do we collect from you and how do we use them? ", and particularly the column "What is the legal basis for processing your Personal Data?" to find out whether our processing is based on consent.

 

The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with the data protection authority of your country to challenge the practices used in terms of Personal Data protection and respect for privacy.

We invite you to contact us using the contact details below before submitting any complaint to the competent data protection authority.

The right to data portability

You have the right to move, copy or transmit data concerning you from our database to another. This only applies to the data you have provided, if the processing is based on your consent or on a contract and is carried out using automated processes. Please consult the table inserted in the section "What Personal Data do we collect from you and how do we use them? ", and particularly the column "What is the legal basis for processing your Personal Data?” to find out whether our processing is contract-based or consent-based.

 

The right to restriction of processing

You have the right to request that we restrict the processing of your Personal Data.

This right means that the processing of data concerning you is limited, so that we can keep the data, but not use or process them.

This right applies in specific circumstances provided for by the GDPR, namely:

●  The accuracy of the Personal Data is contested by the data subject (i.e. you), for a period enabling the data controller to verify the accuracy of the Personal Data;

●  The processing is unlawful and the data subject (i.e. you) opposes its erasure and requests the restriction of their use instead;

●  The data controller (i.e. Labrador) no longer needs the Personal Data for the purposes of processing, but they are still necessary for the data subject to establish, exercise or defend legal rights in court;

●  The data subject (i.e. you) has objected to the processing based on the legitimate interests pursued by the controller during the verification as to whether the legitimate reasons pursued by the controller prevail over time over those of the person concerned.

 

The User may exercise these rights at any time by contacting the dedicated department by one of the following means:

By mail:

By email:

Laurent Rouyrès

Labrador

8, rue Lantiez,

75017 Paris

contact@labrador-company.com

 

The User, to exercise his or her rights, provides Labrador with:

-   The origin of the collection of their Personal Data (contact form, for example);

-   Their identity and contact details.

In the event of "reasonable doubt" as to the identity of the person making the request (for example, in the event of a request made via an unknown email address), and in order to prevent identity theft or risks of homonymy, Labrador may request proof of identity to be provided.

Labrador has one (1) month from receipt of the request to respond, provided that the request is well founded and that it is not manifestly excessive.

The User may also refuse to allow their Personal Data to be used by Labrador at any time.

To do so, the User is invited to click on the unsubscribe links provided in the emails sent by Labrador.

Users are informed that they may, if they believe that their rights have not been respected, file a complaint with the National Commission for Information Technology and Civil Liberties (hereinafter, the "CNIL"). Labrador invites the User to go to the following link for more information: https://www.youronlinechoices.com/uk/.

10.  Managing cookies

A "Cookie" is a text file placed by Labrador on the User’s terminal when browsing using the Service. The cookie records information relating to the User's browsing using the Service and stores information that the User enters during their visit. The use of cookies also makes it possible to offer Users the best user experience. The cookies thus placed are used to:

●  Optimize the ergonomics of the Service and the browsing experience;

●  Remember preferences so that you do not have to enter or download the same information again when you use our Service;

●  Improve the security and speed of our Service.

For information on specific cookies placed through a given website (partners/third parties), please refer to the Cookies table on the partner/third party website.
Labrador informs the User to place the following cookies for the following functions:

14] 

 

Name of the placed cookie

 

Type of placed cookie

 

Origin

Functions

 

Retention period on the device

Cookies_consent_status

 

Functional

 

Optimize the Service experience and ensure its smooth operation:

-    Analyze Internet user connections to the Service;

-    Establish communication between the web server and the browser;

-    Ensure that the Service is correctly displayed depending on the browser's information.

 

 

1 year

Google Analytics

 

 

 

Analytics

Google

 

https://policies.google.com/privacy

 

Anonymous analysis of pages dedicated to the Service visited by the User:

-   Count and monitor the pages visited and the number of visitors;

-   Filter requests from robots;

-   Store anonymous visitor statistics.

 

 

1 year

cookieControlPrefs

Functional

 

Save the User’s cookie consent preferences.

 

6 months

 

 

The User is invited to give their overall consent to the placement of these cookies by clicking on "Accept All" in the information banner at the bottom of the page dedicated to the Service during their browsing. They may also consent to this on a case-by-case basis using the drop-down menu for each type of cookie and associated purposes.

The User can also deactivate all cookies by clicking on the "Refuse all" button in the aforementioned information banner. However, regarding cookies used to improve the ergonomics and operation of the Service, disabling them could prevent you from using certain parts of the Service.

Notwithstanding certain audience measurement cookies, which cannot be configured as they are essential for the proper functioning of the Service, the User may object to the placement of cookies directly from his or her browser as follows: 

●  For Mozilla Firefox: choose the "Tools" menu then "Options" / Click on the "Privacy" icon / Find the "Cookie" menu and select the desired options; 

●  For Microsoft Internet Explorer: select the "Tools" menu then "Internet Options" / click on the "Confidentiality" tab / select the desired level using the slider; 

●  For Opéra 6.0 and later versions: select the menu "File"> "Preferences" / "Privacy"; 

●  For Safari: choose the menu "Edit"> "Preferences" / "Security". Click on "Show cookies" and select the cookies concerned, then click on "Clear" / "Done"; 

●  For Google Chrome: Click on "Tools"> "Options"> "Advanced options", "Confidentiality", "Show cookies" then delete the files concerned. Finally, click on "Close".

Users are informed that the maximum retention period for this information on their device is one (1) year.

The User may also oppose the placement of cookies by going to the advertising cookies management platform offered by advertising professionals at the following address:

https://www.youronlinechoices.com/uk/ and by following the instructions given there.

In any event, Users who have expressed their choices in terms of cookies will no longer be presented with the information banner during their next visits, for a period of six (6) months. The User may, however, have access to their choices and modify them at any time, thanks to the tab "Configure my cookies" which will reopen the stored information banner.

11.  Property

The Service and its various elements are protected by intellectual and industrial property law. Any representation, any reproduction and, more generally, any exploitation for payment or free of charge, for any purpose whatsoever, by any means whatsoever, of all or part of the Service (in particular its general structure, photographs, information, icons, acronyms, logos, graphics, brands, illustrations, texts appearing therein, without this list being exhaustive), for commercial purposes or not, without the prior written authorization of Labrador is forbidden. The information contained via the Service is strictly reserved for personal, private and free use. Any use contrary to this clause constitutes an act of counterfeiting under criminal and civil law.

12.  Hypertext links

Through this Service, the User can access sites designed and managed under the responsibility of third parties.

The User is informed that Labrador has no control over the content of said sites. In addition, Labrador declines all responsibility with regard to their content and the use made by any third party of the information contained therein.

13.  Integrity – Technical Failures

Labrador reserves the right to temporarily interrupt access to the Digital URD Service in order to carry out technical, improvement and maintenance works to ensure its proper functioning or to repair a breakdown.

The User is informed that the security and integrity of Internet communications cannot be guaranteed. Labrador undertakes to make its best efforts to warn the User of any difficulty in accessing the Service or any interruption in the distribution of the online Universal Registration Document, without any performance obligation.

14.  Law and jurisdiction

The applicable law is French law, the competent courts are the French courts in compliance with the rules of the French Code of Civil Procedure.

15.  Changes

This Policy may be modified or supplemented at any time by Labrador for the purposes of updating in accordance with changes in the legislation and regulations in force, subject to informing the User thereof. In case of doubt, the latest version is the one on the page dedicated to the Service.

However, Users’ Personal Data will always be processed in accordance with the policy in force at the time of their collection, unless a mandatory legal requirement were to provide otherwise and be applied retroactively.

16.  Contact

For any question relating to the collection or processing of the data collected, the User is invited to contact Labrador:

-   By telephone: 00 33 (0)153 063080;

-   By mail: Labrador, 8, rue Lantiez, 75017 Paris;

-   By email: contact@labrador-company.com

Any question will always be received with kindness! 

Document dated: April 26, 2021

To obtain further information, you can visit CSW data protection policy.

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