The site ensures that the User collects and processes personal information while respecting privacy in accordance with Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms.
HANDIVISIBLE is attentive to the protection of the personal data of its customers, users, of any person who accesses its website, and in general of any person whose personal data it may be required to process. HANDIVISIBLE is also aware of the need to allow anyone to maintain control over their personal data.
The purpose of this Personal Data Protection Policy is to provide data subjects with important information on how HANDIVISIBLE processes their personal data, and on how data subjects can exercise their rights.
This Personal Data Protection Policy also aims to meet the requirements of the new regulations relating to the protection of personal data (Regulation No. 2016/679) which comes into force from May 25, 2018.
1. Who is responsible for processing personal data?
The data controller is HANDIVISIBLE whose head office is located at 13 Voie des Fontaines – 10600 PAYNS, registered under number 90161565800019, telephone number: +33 664092221, email: maite.ferdinand@jp-superadmin-handivisibleThis personal data protection policy concerns the processing carried out by HANDIVISIBLE as data controller.
2. For what reasons/purposes, and on what legal bases are personal data processed?
HANDIVISIBLE processes your personal data:
– For user relationship management, (legitimate interest),
– For the management of responses to contact requests, (Consent),
– For the management of cookies (Consent and Legitimate Interest),
– For the management of newsletter subscriptions, (Consent),
– For the management of possible fraud (legitimate interest),
– For the management of requests to exercise rights linked to the GDPR (legal obligation),
– For the management of complaints and disputes (legal obligation and legitimate interest).
The processing of personal data carried out by HANDIVISIBLE is based on legal obligation and legitimate interest.
For more details, we invite you to consult the sections below. HANDIVISIBLE may process personal data for the following purposes:
Processing based on consent:
– Managing contact requests, Managing newsletter subscriptions.
– Management of cookies (Geolocation or containing indirect personal data).
Processing based on legal obligation:
– Managing requests to exercise rights linked to the GDPR, Management of complaints and disputes.
Processing based on legitimate interest:
– Management of commercial relationships,
The legitimate interest pursued is that of continuing or renewing an existing commercial relationship with a user who has shown an interest in the services.
Cookie management,
The legitimate interest pursued is to be able to measure the audience of the website and the different pages, as well as the interaction rate anonymously.
Control of possible fraud,
The legitimate interest pursued is to be able to control possible fraud and take the necessary measures, including the exclusion of a user when fraud is observed,
Management of complaints and disputes,
The legitimate interest pursued is that of being able to ensure legal protection in the event of a complaint or dispute,
3. What categories of personal data are processed?
HANDIVISIBLE may process personal data relating to the means of contacting you, such as your email address.
The notion of “personal data” means any information relating to an identified or identifiable natural person.
For more details we invite you to consult the sections below.
HANDIVISIBLE may process personal data relating to: Your email address and your identity linked to the voluntary contact or your subscription to the newsletter.
4. Cookies and Social Networks
HANDIVISIBLE.FR may use “cookies” or tracers (file of limited size, generally consisting of letters and numbers, sent by the internet server to the browser cookie file located on the hard drive of your computer) in order in particular to enable or facilitate your navigation on the HANDIVISIBLE.FR website, optimise the use of the website and produce visit or geolocation statistics.
You will be informed clearly and completely before installing a “cookie” so that HANDIVISIBLE obtains your agreement, except when the “cookie” has the exclusive purpose of allowing or facilitating communication by electronic means or is strictly necessary for the provision of an online communication service according to an express request from you.
The GDPR also authorises the deposit of anonymous cookies or tracers intended for statistical measurements which do not allow you to be identified and intended solely for HANDIVISIBLE without transfer to third parties, cookies or tracers intended to preserve your choice in terms of cookies and tracers, the cookies and tracers linked to your authentication, your shopping cart, billing or access limitation.
In any case, you have, in application of the regulations, a right of access, opposition, rectification and deletion of personal data which may be collected through these cookies and trackers. These rights are recalled in article 9 of this Personal Data Protection Policy.
– You have (if available) the possibility of clicking on the icons dedicated to social networks appearing on the HANDIVISIBLE.FR website. Social networks make it possible to improve the user-friendliness of sites and facilitate their promotion via possible sharing.
These features use third-party cookies intended to improve the interactivity of the site which are directly deposited by these services. When you click on these links, the organisation concerned may have access to the personal information that you have indicated as public and accessible from your profiles on social networks. However, HANDIVISIBLE does not create or use any database independent of social networking sites from the personal information that you may publish there and HANDIVISIBLE will not process any data relating to private life through this means. If you do not want HANDIVISIBLE to have access to personal information published in the public area of your profiles or social accounts, you must then use the means made available to you by social networks in order to limit access to this data.
HANDIVISIBLE is in no way responsible for the uses of your data made by third-party organizations using HANDIVISIBLE and integrating links to their social networks.
5. To whom can personal data be transmitted?
Your personal data is communicated to HANDIVISIBLE internal services which need your personal data for the purposes mentioned above, to HANDIVISIBLE subcontractors for mainly technical reasons such as database management or website maintenance, to HANDIVISIBLE partners as part of an explicit request from you or for the management of the services offered.
For more details, we invite you to consult the sections below.
HANDIVISIBLE may transmit personal data to different categories of recipients:
– HANDIVISIBLE’s management, sales, IT, after-sales service and administrative services: personal data is transmitted to HANDIVISIBLE’s internal services which need to process them for the purposes mentioned above.
– Department responsible for litigation: personal data in intermediate archives is accessible only to authorised internal persons.
– Service in charge of requests for the exercise of rights (GDPR): personal data is accessible only to people in charge of requests for the exercise of rights,
– Subcontractors: personal data may be transmitted to subcontractors with a view to carrying out technical missions (for example database management, sending prospecting, data hosting) entrusted to them by HANDIVISIBLE in the framework of its activity.
– Technical and IT service providers in charge of managing the HANDIVISIBLE.FR website: the HANDIVISIBLE.FR website is managed and hosted by IT service providers and personal data, particularly relating to the connection, are processed by these service providers.
HANDIVISIBLE undertakes not to transfer personal data to third parties whose activity or purpose is the acquisition of new prospects with a view to sending commercial prospecting without express agreement from the person concerned.
HANDIVISIBLE may be required to communicate personal data to comply with a legal obligation, at the request of an administrative or judicial authority which requests it or for the exercise of a legitimate interest such as the defence of its rights.
6. How are personal data collected?
Personal data may be collected directly by HANDIVISIBLE when a person sends a contact request. Personal data is only collected during a voluntary act of the person.
7. How long are personal data kept?
Your personal data is kept for the period necessary to achieve the purposes for which it was collected and is archived beyond this period when it is deemed necessary in order to meet legal obligations or to assert a legal right. . More particularly, your personal data is kept for use according to the relationships provided.
For more details, we invite you to consult the sections below.
Your personal data is kept on an active basis and used for different periods depending on the purposes described above. More specifically:
For the management of responses to contact requests, (Consent) → Conservation for the time necessary to provide a response,
For the management of newsletter subscriptions, (Consent) → Conservation until consent is withdrawn or 3 years from the last action on your part regarding the processing,
For the management of cookies, (Consent) → Until consent is withdrawn or 1 month,
For the management of possible fraud (legitimate interest) → Conservation in an archived database for the duration of the dispute,
For the management of requests to exercise rights linked to the GDPR (legal obligation) → Conservation in active database for 1 year, then intermediate archiving for 5 years,
For the management of complaints and disputes (legal obligation and legitimate interest) → Conservation of the time necessary to process the complaint or dispute. The decisions handed down will be permanently archived for historical interest,
The personal data necessary for the execution of a contract are kept and used throughout the duration of the said contract.
Without prejudice to the possibility of objecting or withdrawing consent at any time to this processing, personal data which are processed for commercial prospecting purposes for HANDIVISIBLE products or services are kept for a period of 3 years from last contact from you with HANDIVISIBLE.
Certain personal data is archived beyond the retention period described above in order to meet a legal obligation or to assert a legal right.
8. Security
HANDIVISIBLE implements all technical and organisational measures to ensure the security of the processing of your personal data as well as their confidentiality.
To ensure the security of your personal data, in particular to prevent it from being distorted, damaged, or from unauthorised third parties having access to it, HANDIVISIBLE takes all necessary precautions, taking into account the nature of the data and the risks presented by the processing (in particular through the physical protection of premises, the implementation of authentication processes with personal and secure access via confidential identifiers and passwords, logging of connections, encryption of certain data.).
9. What are your rights relating to the processing of your personal data?
In accordance with the regulations, you have the right to access your personal data, to rectify it, to oppose its processing or to obtain its limitation, erasure or portability when applicable.
Furthermore, you can at any time withdraw your consent for processing based on it, or request to no longer receive our communications relating to offers, news or events by contacting HANDIVISIBLE (see Article 3, Paragraph 1).
You can lodge a complaint with the CNIL if you consider that your rights have not been respected.
For more details on your rights, we invite you to consult the sections below.
Depending on the processing, you benefit from the following rights:
Right of opposition: you have the right to object at any time to the processing of your personal data:
– for prospecting purposes, without justifying any particular reason;
– for all other purposes, in relation to processing based on the legitimate interest of HANDIVISIBLE, for reasons relating to your particular situation, unless HANDIVISIBLE demonstrates that there are legitimate and compelling reasons which override your interests and rights and freedoms, or for the establishment, exercise or defense of legal rights.
– Right of access: you have the right to obtain confirmation whether or not your personal data are processed by HANDIVISIBLE and when they are, to obtain communication of the information concerning you which is processed by HANDIVISIBLE.
– Right of rectification: you have the right to obtain the rectification of inaccurate or incomplete information concerning you and which is processed by HANDIVISIBLE.
– Right to withdraw your consent: you can, for processing based on consent, withdraw the consent you have given for processing at any time.
– Right to limit processing: you have the right to have the processing of personal data suspended until a verification can be carried out (verification of the accuracy of the information, the legal bases of the processing, the legitimate reasons for HANDIVISIBLE when you are opposed to the processing) or when the processing is unlawful but you object to their erasure.
– Right to define directives relating to the fate of your personal data after your death: you have the right to provide directives concerning the fate of your personal data after your death. In the absence of such instructions, your heirs may, after your death, exercise these rights over your personal data.
– Right to erasure or right to be forgotten: you have the right to obtain the erasure by HANDIVISIBLE of your personal data when one of the following reasons applies: (i) the data is no longer necessary for the purposes for which they were collected; (ii) you withdraw your consent to the processing and there is no other legal basis for the processing; (iii) you object to the processing of your personal data and there is no overriding legitimate ground for the processing; (iv) the data is subject to unlawful processing; (v) the data must be erased to comply with a legal obligation.
– Right to portability: you have the right to obtain the personal data you have provided to HANDIVISIBLE in a structured, commonly used and machine-readable format so that you can transmit it or you can ask HANDIVISIBLE to transmit it, when this is technically possible, to another data controller. This right is applicable when the processing is based on your consent or on the performance of a contract and is carried out using automated processes.
– Right to lodge a complaint with the National Commission for Information Technology and Liberties (CNIL): you have the right to lodge a complaint with the CNIL if you consider that HANDIVISIBLE does not comply with the obligations provided for by the regulations relating to to the protection of personal data (https://www.cnil.fr/).
10. How to exercise your rights relating to your personal data?
Generally speaking, to exercise your rights and for any questions or difficulties relating to the processing of your personal data and your rights, you can contact HANDIVISIBLE:
By email: maite.ferdinand@handivisible.fr
For more details, we invite you to consult the sections below.
If you no longer wish to receive advertisements from HANDIVISIBLE:
For offers sent by email by HANDIVISIBLE: you can make the request by post or electronically, or use the link provided for this purpose in the footer of each email,
For offers by telephone: you can register your telephone numbers on the Bloctel telephone canvassing opposition list: https://conso.bloctel.fr/index.php. Or inform HANDIVISIBLE during a call.
If you wish to have your personal data processed by HANDIVISIBLE corrected, deleted or accessed:
You can send HANDIVISIBLE your request accompanied by a copy of your identity document by post or electronically.
If you wish to withdraw your consent to processing:
You can withdraw your consent to processing of your personal data based on such a basis at any time by sending your request including the information necessary for processing it by post or electronic means, or by using the link provided for this purpose, for example, in the footer of an email.
If you wish to object to processing:
You can at any time object to the processing of your personal data for commercial prospecting purposes by sending your request by post or electronically.
You can object to the processing of your personal data for reasons/purposes other than commercial prospecting by sending your request accompanied by a copy of your identity document by post or electronically.
If you wish to obtain limitation of the processing of your personal data carried out by HANDIVISIBLE or obtain portability of your personal data:
You can send your request including the information necessary to process it accompanied by a copy of your identity document by post or electronically.
If you wish to give instructions regarding your personal data after your death:
You can exercise this right by writing and providing a copy of your identity document by post or electronically.
This version was updated on November 29, 2021.