Charter on the processing of personal data – WETRUF website
- INTRODUCTION – IDENTITY OF THE DATA CONTROLLER
As a preliminary matter, capitalized terms are defined in II below.
WETRUF – a simplified joint stock company whose registered office is located at 2, avenue de la Forêt de Haye in Vandœuvre-Lès-Nancy (54500) and registered in the Nancy Trade and Companies Register under number 878 262 526 – is considered to be the Data Controller for the Personal Data collected via the Website.
This charter on the processing of personal data (the ” Charter “) is intended to provide persons (the ” Users “) browsing the Website and, where applicable, planning to order Services or having ordered Services, with information relating to the terms and purposes of the processing of Personal Data by WETRUF.
The purpose of the Charter is to inform Users of the means implemented by WETRUF to protect their Personal Data. More generally, the purpose of the Charter is to inform the Users about the applicable regulations relating to Personal Data and to allow them to exercise their rights in this respect.
WETRUF is particularly committed to the protection of personal data.
WETRUF thus intends to comply with the relevant regulations in force, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of personal data and the free movement of such data (the ” GDPR “) which came into force in France on May 25, 2018, and the law of January 6, 1978 known as ” Informatique et Libertés ” in its latest version in force.
Therefore, all Personal Data collected by WETRUF via the Website will be used in accordance with the terms and conditions set out in the Charter, and in compliance with the regulations in force.
In addition to the terms defined in I. above, for the purpose of understanding and interpreting this Charter, essential terms are defined as set forth below:
- ” Personal Data ” means any information relating to an identified or identifiable natural person. An “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier or one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.
- ” Sensitive Data Personal Data” means Personal Data that reveal the alleged racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning the sex life or sexual orientation of a natural person.
- ” Services” means the services performed by WETRUF, including training, for which Users can place orders on the Website.
- “Data Processor ” means, in the sense of the regulations in force concerning the protection of Personal Data, the entity that determines the means and purposes of the Processing of Personal Data.
- ” Website ” means the e-commerce website http://wetruf.com/en/.
- ” Subprocessor” means the natural or legal person, public authority, department or any other body that processes Personal Data on behalf of the Controller.
- ” Processing of Personal Data “means any operation or set of operations, whether or not carried out using automated processes, applied to data or sets of Personal Data, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or otherwise making available, alignment or combination, limitation, erasure or destruction.
- ” User” means any natural person browsing the Website and/or planning to order Services on the Website.
- ” Personal Data Breach” means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
As the context requires, the terms defined in this Article II. may be written in the singular or plural in this Charter.
- PERSONAL DATA PROCESSING CARRIED OUT BY WETRUF AND ITS PURPOSES
WETRUF only collects Personal Data from Users that is relevant, adequate and limited to what is necessary in view of the purposes for which such Personal Data is Processed, and in accordance with the principles of Purpose and Relevance enshrined in the GDPR.
These purposes are set out below:
- to answer the questions of the Users sent via the contact form;
- create an account allowing Users to place orders for Services;
- send newsletters by email to Users (if the User has filled in the newsletter registration form);
- to ensure the quality of its services to Users, in particular by maintaining and improving its Internet Site;
- to carry out studies on the typology of the Users and to produce statistical data;
In view of the purposes set forth above, WETRUF necessarily collects certain Personal Data relating to Users.
WETRUF’ s use of the User’s Personal Data collected via the contact form on the Website is necessary in order to answer the User’s questions.
In addition, WETRUF’ s use of the User’s Personal Data collected via the customer account creation form is necessary to enable the User to place orders for Services.
- LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA BY WETRUF
When browsing the Website and, where applicable, when ordering Services, Users are expressly informed of the purposes stated above for which their Personal Data are collected, and this, via the various forms and this Charter.
The Processing of Personal Data listed in III. above are thus based on the prior consent of the User concerned.
The use of certain Personal Data collected via Cookies is also based on the User’s consent (see X on Cookies).
This consent is formalized by the User’s express acceptance, in particular by a checkbox, of the collection by WETRUF of the Personal Data that the User has entered for the purpose(s) stated above.
The fields marked with an “*” on the various forms accessible via the Website are mandatory with regard to the purposes for which they are processed. If the User does not provide this “mandatory” Personal Information, WETRUF will not be able to properly process the User’s request, including ordering Services.
The other fields (optional) are intended to allow the User to specify his request. The User is then free to fill in or not all or part of the information requested.
- TYPOLOGY OF PERSONAL DATA PROCESSED – ENUMERATION
In view of the above-mentioned purposes, WETRUF may process the Personal Data of the Users listed below:
- Full name;
- Position held in the company and name of the company;
- Mailing address;
- Email address;
- Cell phone number.
In addition, WETRUF does not collect any Sensitive Data about Users.
- MEASURES IMPLEMENTED TO SECURE PERSONAL DATA
WETRUF implements technical and organizational measures to ensure the security of the Processing of Users’ Personal Data and, more generally, the confidentiality of such Personal Data.
For this purpose, WETRUF has taken adequate measures, particularly in view of the type of Personal Data processed, to protect the security of such Personal Data, and in particular to prevent it from being altered and/or damaged and/or accessed by unauthorized third parties, including: protection of the premises of WETRUFauthentication processes and computer stations protected by confidential identifiers and passwords, etc.
Furthermore, in accordance with the applicable regulations, in the event of the occurrence of an event that would affect the Personal Data and would be likely to prejudice the rights of the Users, WETRUF will inform the competent control authority as soon as possible. In the event of an objectively high risk of a breach of Personal Data, WETRUFenwill inform the Users concerned, either individually or in groups, depending on the circumstances, as soon as possible.
- RETENTION PERIOD OF PERSONAL DATA
WETRUF shall keep Users’ Personal Data in an “active base” only for as long as is necessary for the purposes for which it is to be used, in accordance with legal requirements and the recommendations of the relevant authorities.
The User’s Personal Data is kept by WETRUF for the duration of the business relationship between WETRUF and the User and for a period of five(5) years from the last exchange between WETRUF and the User.
At the expiration of the aforementioned period of five (5) years, WETRUF may, if it deems it relevant, keep in “intermediate storage” the Personal Data of the Users for an additional period of ten (10) years, solely for the purposes of statistical analysis and compliance with its legal and regulatory obligations, and in the context of controls carried out by the Administration and/or during litigation.
- RECIPIENTS OF PERSONAL DATA
WETRUF does not pass on any User’s Personal Information to commercial or advertising entities.
The Personal Data of the Users are processed by the staff of WETRUF. WETRUF ‘s staff is highly aware of the importance of protecting Personal Data and, more generally, of preserving the confidentiality of data relating to Users.
WETRUF created the Website using the WordPress tool.
WETRUF only works with a limited number of service providers for the hosting and continuous improvement of its website. These Providers are listed below:
- the IT service provider in charge of hosting the Site:
1&1 IONOS S.A.R.L
Siret : 431 303 775 00016
Share capital: 100 000 €.
7 Place de la Gare
- independent providers :
- Jérôme NAU (development aid)
- Morgane GILLARD (help on SEO writing)
It is nevertheless specified that, given their functions, the above-mentioned service providers are not authorized to access the Personal Data of Users. They are therefore not subcontractors of WETRUF within the meaning of the current regulations on Personal Data.
If the above-mentioned service providers or, possibly, other service providers, were to access the Personal Data of Users, this would only be to ensure an even more ergonomic and secure use of the Website. In any case, access to Users’ Personal Data will be done in accordance with the applicable regulations.
Finally, WETRUF may disclose Users’ Personal Data to third parties when such disclosure is required by law or regulation or by a court order, or if such disclosure is necessary to protect and defend legitimate interests.
- TRANSFER OF PERSONAL DATA ABROAD
The Personal Data of Users collected by WETRUF is not transferred outside the European Union.
- USERS’ RIGHTS – HOW TO EXERCISE THEM
In accordance with the regulations in force, any User may effectively exercise the rights he or she holds in application of the regulations on the protection of personal data, namely: right ofaccess, right to rectification, the right to limit the processing ofhisPersonal Data, the right to deletion (“right to be forgotten”) and the right toobject to the processing of his Personal Data.
In order to exercise these rights, the User can send an email to WETRUF at the address : email@example.com or by mail to this address: 2, avenue de la Forêt de Haye à Vandœuvre-Lès-Nancy(54500).
In order for WETRUF to be able to respond promptly, the User must provide WETRUF with the following information: last name, first name, email address, and the precise and clearly stated purpose of the request.
WETRUF may request a copy of an ID to verify the User’s identity. A reply will then be sent to the User within one(1) month of the date of receipt of the request.
In addition, the User has the right to file a complaint with the CNIL (Commission Nationale de l’Informatique et des Libertés), in particular via its website: https://www.cnil.fr/.
WETRUF has appointed a data protection officer to its team: Flora TODESCO.
Independently of the exercise of their above-mentioned rights, Users can contact this referent at the email address : firstname.lastname@example.org .
A cookie is (CNIL definition) a small computer file, a tracer, deposited and read, for example, when consulting a website, reading an e-mail, installing or using a software or a mobile application, whatever the type of terminal used (computer, smartphone, digital reader, video game console connected to the Internet, etc.).
The data collected via cookies does not directly identify Users. They are mainly used to allow the proper functioning of the Website, in order to provide Users with an optimized user experience.
They are also used to carry out statistics and measurements relating to the frequentation of the Website.
- cookies that are strictly necessary for the operation of the Website: they are essential for Users to browse the Website, to enable them to use the Website’s features and to place orders for Services.
- audience measurement cookies: these traffic log cookies are used to identify the pages visited and to measure and track the performance of the Website. They are used for the purpose of improving the Website and for statistical analysis.
The User may, at any time, manage cookies by changing the settings in the taskbar of his or her Internet browser.
- INTERPRETATION – MODIFICATION OF THIS CHARTER
The use of the term ” including ” in this Charter means that the enumeration which follows it, or which precedes it, is not exhaustive and thus does not have a limitative character.
This Policy may be amended at any time by WETRUF, in particular to reflect changes in regulations, the Website and, more generally, the business of WETRUF.
These changes will apply automatically to Users. Consequently, each User is invited to regularly consult the present Charter in order to take note of the last version in force.
- REPRODUCTION IS FORBIDDEN
The present Charter was written to measure for WETRUF. Any use or reproduction of the Charter as a whole or of a part of the clauses which it contains, including partially or by way of modification and/or adaptation, is prohibited, except for the company WETRUF.