1. Parties and Purpose

Guillaume de Baudus (hereinafter “Guillaume de Baudus” or the “Controller“)

1 Bernard Palissy Street
92310 Sèvres
France

Guillaume de Baudus establishes the present Privacy Policy, the purpose of which is to transparently inform Users of the website hosted at the following address: www.guillaumedebaudus.eu, (hereinafter the “Site”), of the manner in which personal data is collected and processed by Guillaume de Baudus.

The term “User” refers to any user, either a natural or legal person, who visits or interacts in any way with the Site.

As such, Guillaume de Baudus determines all the technical, legal and organizational means and purposes of processing the personal data of Users. To this end, Guillaume de Baudus undertakes to take all necessary measures to ensure that the processing of personal data complies with the Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter, “the Law”) and the European Regulation of 26 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, “the Regulation”).

Guillaume de Baudus is free to choose any natural or legal person who processes users’ personal data at its request and on its behalf (hereinafter the “Subcontractor”). If necessary, Guillaume de Baudus undertakes to select a Subcontractor offering sufficient guarantees as to the technical and organisational security measures for the processing of personal data, with regard to the Law and the Regulation.

2. Processing of personal data

The use of the Site by Users may result in the communication of personal data. The processing of these data by Guillaume de Baudus, in his capacity as Data Controller, or by service providers acting in the name and on behalf of Guillaume de Baudus, will be in accordance with the Law and the Regulations.

Personal data will be processed by Guillaume de Baudus, in accordance with the purposes mentioned below, via :
an automated procedure; the newsletter registration form; the contact form; the comment form; the use of cookies; the sending of surveys or questionnaires; the sharing of free content.

3. Purpose of the processing of personal data

In accordance with article 13 of the Regulations, the purposes of the processing of personal data are communicated to the User and are as follows:

1. to ensure the execution of the services proposed and agreed upon on the Site and by the user license;
2. to ensure the control of the execution of the proposed services;
3. to carry out marketing activities and promotional information with the prior consent of the User and until revocation of such consent, for example the sending of promotions on the products and services of the Data Controller;
4. answering the User’s questions;
5. to produce statistics in order to improve the Website, the services offered and the internal organization of operation;
6. to improve the quality of the Website and of the products and/or services offered by the Data Controller;
7. to allow a better identification of the User’s centres of interest.

4. Personal data that may be processed

The User consents, when visiting and using the Site, that Guillaume de Baudus collects and processes, according to the methods and principles described in this Privacy Policy, the following personal data:

1. Information from Users that they give for contractual purposes and to enable the proper performance of reciprocal obligations, namely surname, first name, address, IBAN number and bank details, …; and more generally, any information voluntarily given by the User;
2. User information by filling in forms or contacting by telephone, e-mail address or other means, for example the name, address, e-mail address and telephone number of Users.
3. With respect to each User’s visits to the Site, the information automatically collected is;
   • IP address, browser type and model, time zone, operating system;
   • all information concerning the pages that the User has consulted on the Site, including the URL, navigation time, etc.

5. Consent

By accessing and using the Site, the User declares that he or she is aware of and agrees freely, specifically, knowingly and unequivocally to the processing of personal data concerning him or her. This agreement relates to the content of this Privacy Policy.

Consent is given by the positive act by which the User has ticked the box proposing the Privacy Policy in the hyperlink. This consent is an indispensable condition to carry out certain operations on the Site or to allow the User to enter into a contractual relationship with Guillaume de Baudus. Any contract between Guillaume de Baudus and a User concerning the services and goods offered on the Site is subject to the User’s acceptance of the Privacy Policy.

The User consents that the Data Controller processes and collects, in accordance with the terms and principles included in this Privacy Policy, his/her personal data that he/she communicates on the Site or during the services offered by Guillaume de Baudus, for the purposes indicated above.

The User has the right to withdraw his/her consent at any time. Withdrawal of consent does not compromise the lawfulness of the processing based on the consent previously given.

6. Storage period of Users’ personal data

In accordance with Article 13 §2 of the Regulation and the Law, the Data Controller shall only keep personal data for the time reasonably necessary to allow the fulfilment of the purposes for which they are processed. This period is in any case less than : 3 years.

7. Recipients of data and disclosure to third parties

Personal data may be transmitted to Guillaume de Baudus’ employees, collaborators, subcontractors or suppliers who offer adequate data security guarantees and who collaborate with the Data Controller in the context of the marketing of products or the provision of services. They act under the direct authority of Guillaume de Baudus, and are in particular responsible for collecting, processing or subcontracting this data.

In all cases, the recipients of the data and those to whom the data has been disclosed shall comply with the content of this Privacy Policy. Guillaume de Baudus assures that they will process these data solely for the purposes intended, in a discreet and secure manner.

Should the data be disclosed to third parties for direct marketing or canvassing purposes, the User will be informed beforehand so that he can express his consent to the use of this personal data.

8. Data Protection Officer (DPO)

The following person is appointed Data Protection Officer (hereafter “DPO”): Christophe Lefèvre

The role of the DPO is to ensure the proper implementation of national and supranational provisions on the collection and processing of personal data.

The DPO can be contacted as follows: by e-mail at admin@guillaumedebaudus.eu or by telephone at +32 495 99.83.18.

9. Users’ Rights

At any time, the User may exercise his/her rights by sending a message by e-mail to the following address: admin@guillaumedebaudus.eu, or a letter by post, enclosing a copy of his/her identity card to the following address: 1, rue Bernard Palissy, 92310 Sèvres, France.

a. Right of access

In accordance with article 15 of the Rules, Guillaume de Baudus guarantees the User’s right of access to his personal data.

The User has the right to obtain access to the said personal data as well as the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular recipients who are established in third countries or international organisations;
• where possible, the intended period of storage of the personal data or, where that is not possible, the criteria used to determine that period ;
• the existence of automated decision making, including profiling, as referred to in Article 22(1) and (4) of the Regulation, and, at least in such cases, relevant information concerning the underlying logic, as well as the importance and the expected consequences of the processing for the data subject

The Data Controller may require payment of a reasonable fee based on administrative costs for any additional copies requested by the User.

Where the User submits such a request electronically (e.g. via e-mail address), the information is provided in a commonly used electronic form, unless the User requests otherwise.

A copy of the User’s data will be communicated to the User at the latest within one month after receipt of the request.

b. Right of rectification

Guillaume de Baudus guarantees the user’s right to correct and delete personal data.

In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or erased at any time. The User first makes the necessary changes himself/herself from his/her user/other account, unless they cannot be made autonomously, in which case the request can be made to Guillaume de Baudus.

In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been communicated of any rectification of the personal data, unless such communication proves impossible or requires disproportionate efforts. The Controller shall provide the data subject with information about these recipients if the data subject so requests.

c. Right of erasure

The User has the right to obtain the deletion of his/her personal data as soon as possible in the cases listed in article 17 of the Regulations.

Where the Controller has made the personal data public and is required to erase them pursuant to the previous paragraph, the Controller, taking into account the available technologies and the costs of implementation, shall take reasonable measures, including technical measures, to inform the other controllers processing such personal data that the data subject has requested the erasure by those controllers of any link to such personal data, or any copy or reproduction thereof.

The two preceding paragraphs shall not apply to the extent that such processing is necessary:

for the exercise of the right to freedom of expression and information;

to comply with a legal obligation which requires the processing to be carried out in accordance with Union law or the law of the Member State to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

the establishment, exercise or defence of legal claims.

In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been disclosed of any erasure of personal data or any restriction on the processing operation carried out, unless such notification proves impossible or involves a disproportionate effort. The Controller shall provide the data subject with information about these recipients if the data subject so requests.

d. Right to Limit Treatment

The User has the right to obtain the limitation of the processing of his/her personal data in the cases listed in article 19 of the Regulations.

In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data have been communicated of any limitation of the processing carried out, unless such communication proves impossible or requires a disproportionate effort. The Controller shall provide the data subject with information about these recipients if the data subject so requests.

e. Right of data portability

In accordance with Article 20 of the Rules, Users have the right to receive from Guillaume de Baudus personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit these data to another data controller without Guillaume de Baudus obstructing them in the cases provided for in the Rules.

Where the User exercises his right to data portability pursuant to the previous paragraph, he has the right to obtain that personal data be transmitted directly from one controller to another, where this is technically possible.

The exercise of the right of data portability shall be without prejudice to the right of erasure. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. The right of data portability shall not prejudice the rights and freedoms of third parties.

f. Right of opposition and automated individual decision making

The User has the right at any time to oppose the processing of his personal data due to his particular situation, including the automation of data by Guillaume de Baudus. In accordance with Article 21 of the Regulation, Guillaume de Baudus will no longer process personal data, unless there are legitimate and compelling reasons for the processing that prevail over the interests and rights and freedoms of the User, or for the ascertainment, exercise or defence of legal rights.

Where personal data is processed for canvassing purposes, the User has the right to object at any time to the processing of personal data concerning him/her for such canvassing purposes, including profiling insofar as it is related to such canvassing. Where the data subject objects to the processing for canvassing purposes, the personal data shall no longer be processed for such purposes.

g. Right of complaint

The User has the right to file a complaint concerning the processing of his personal data by Guillaume de Baudus with the Data Protection Authority, competent for French territory. Further information can be found on the website: http://www.cnil.fr/.

Complaints can be submitted to the following addresses:

Commission Nationale de l’Informatique et des Libertés – CNIL, 8 rue Vivienne, CS 30223, 75002 Paris, Cedex 02. Tel: +33 1 53 73 22 22. Fax +33 1 53 73 22 22 00.

The User may also file a complaint with the Court of First Instance of his domicile.

10. Cookies

The Site uses cookies to distinguish the Users of the Site. This helps to provide Users with a better browsing experience and an improvement of the Site and its content. The objectives and modalities of cookies are contained in this article.

a. General principles

A “Cookie” is a file that is temporarily or permanently deposited on the User’s hard disk when consulting the Website, with a view to later connection. Thanks to cookies, the server recognises the User’s computer. Cookies can also be installed by third parties with whom Guillaume de Baudus collaborates. Some of the cookies used by Guillaume de Baudus are necessary for the proper functioning of the Website, others allow to improve the User’s experience. The User can personalize or deactivate cookies by setting up his browser. By using the Website, the User expressly agrees with the management of cookies as described in this article.

b. Type of cookies and purposes

Different types of cookies are used by Guillaume de Baudus on the Site:

Technical cookies: they are necessary for the operation of the Website, allow the communication of the data entered and are intended to facilitate the User’s navigation;

Cookies for statistical and audience measurements: these cookies allow the recognition of the User and are used to count the number of Users of the Website over a certain period of time. Since they also indicate browsing behaviour, they are an effective means of improving the User’s browsing by displaying proposals and offers that may be of interest to him/her. They also allow Guillaume de Baudus to identify possible bugs on the Website and to correct them.

Functional cookies: these cookies facilitate the use of the Website by retaining certain choices introduced (for example, the user name or the language);

Tracking cookies: Guillaume de Baudus uses tracking cookies via Google Analytics to measure the interaction of Users with the content of the Website and to produce anonymous statistics. These statistics allow Guillaume de Baudus to improve the Website. Google supports the explanation of these cookies at the following address: http://www.google.nl/intl/en_uk/policies/privacy/.

c. Cookie Retention Time

Cookies are kept for the time necessary to achieve the intended purpose. The cookies that may be stored on the User’s hard drive and their retention period are as follows:

• Google analytics: 6 months – Google tag managment: 6 months
• Facebook pixel: 6 months
• Linkedin pixel: 6 months
• Pinterest: 6 months

d. Cookie management

If the User does not want the Website to place cookies on his hard disk, he can easily manage or delete them by modifying the parameters of his browser. Browser programming also allows the User to receive a notice or notification as soon as a Website uses cookies and thus decide whether to accept or reject them.

If the User deactivates certain cookies, he/she accepts that the Website may not function optimally. Certain parts of the Website may therefore not be usable, or may only be partially usable.

If the User wishes to manage and/or delete certain cookies in this way, he or she can do so by using the following link(s):

For Users with the following browser:

• Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
• Microsoft Edge: http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
• Chrome: https://support.google.com/accounts/answer/61416?hl=fr – Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
• Safari: https://support.apple.com/kb/ph21411?locale=fr_CA

If the User refuses to allow the use of cookies from Google Analytics, he/she is invited to set his/her browser to this effect on the following website: http://tools.google.com/dlpage/gaoptout.

11. Limitation of liability of the Data Controller

The website may contain links to other websites owned by third parties not related to Guillaume de Baudus. The content of these sites and their compliance with the Law and Regulations is not the responsibility of Guillaume de Baudus.

The holder of parental authority must give his express consent for a minor under 16 years of age to disclose personal information or data on the website. Guillaume de Baudus strongly advises persons exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for collecting and processing information and personal data from minors under the age of 16 whose consent is not effectively covered by that of their legal parents or for incorrect data – particularly concerning age – entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he/she is under 16 years of age.

Guillaume de Baudus is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or following computer attacks.

12. Security

The Data Controller implements organisational and technical measures to guarantee an appropriate level of security for the processing and collection of data. These security measures depend on the costs of implementation in relation to the nature, context and purposes of the processing of personal data. The Data Controller uses standard encryption technologies within the IT sector when transferring or collecting data on the Site.

13. Changes to the Privacy Policy

Guillaume de Baudus reserves the right to modify this Privacy Policy in order to comply with legal obligations in this regard. The user is therefore invited to regularly consult the Privacy Policy in order to be aware of the modifications and adaptations. Any such modification will be posted on the Site or sent by e-mail for purposes of enforceability.

14. Applicable law and jurisdiction

This Privacy Policy is governed exclusively by French law. Any dispute will be brought before the courts of the judicial district of the registered office of Guillaume de Baudus.

15. Contact

For any questions or complaints relating to this Privacy Policy, the User may contact the Data Controller via the following address: admin@guillaumedebaudus.eu.