Data privacy and cookies

The purpose of this charter (hereinafter the “Charter”) is to inform users (hereinafter, individually, the “User” and, collectively, the “Users”) of the website and mobile site http://m.choozen.co.uk (hereinafter the “Site”) of the means implemented for:

 

(1) collecting personal data, in compliance with the current version of Law no. 78-17 of 6 January 1978 relative to computing, files and data privacy (hereinafter the “French data privacy Act”) As well as (EU) Regulation 2016/679 of the European Parliament and Council of 27 April 2016 relative to the protection of natural persons with respect to the processing of personal data and the free circulation of such data, and repealing the directive 95/46/EC (hereinafter the “GDPR”);

 

(2) consulting and conserving information relative to the User’s browsing on the Site likely to be saved in “cookie” files (hereinafter the “Cookie(s)”).

 

The company in charge of collecting the personal data is LeGuide.com, a simplified joint-stock company listed on the Paris of Trade and Companies Registry under the no. 425 085 875, headquartered at 12, rue Godot de Mauroy, 75009 Paris – France (hereinafter the “Publisher”).

 

The Charter can be amended at any time by the Publisher, to comply with changes in the regulations, case law, editorial line or technology. Before browsing, the User should refer to the latest version of the Charter.


 

The competent national supervisory authority for the transborder processing of personal data carried out by the Publisher is the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy - TSA 80715 - 75334 Paris CEDEX 07, France. 


 

  1. DATA PRIVACY

 

When the User is using the Site, data is likely to be collected and processed to allow access to the services on the Site (hereinafter the “Services”) for the purposes of administrative and commercial management.

 

1) WHAT DATA IS COLLECTED?

 

      1. User account data: this is the data the User fills in when creating an account by filling in the registration form.

 

      1. Data rendered public by the User: This is all information the User displays voluntarily on the Site, such as comments on blogs and forums, photos, discussions on the forums, and the profile of the account. Only the data the registered User has expressly declared public can be published like this, by enabling the online mechanism called “Information to be disseminated” (hereinafter “Public data”).


 

      1. Data relative to browsing: the data the Publisher collects when the User is browsing on the Site, such as the date, time of the connection and/or browsing, the type of browser, the browser language and the IP address.

 

All of this Data will be collectively called, hereinafter, the “data”.

 

2) WHY DOES THE PUBLISHER COLLECT USER DATA?

The Data gathered within the scope of the use of the Site is subject to processing for the following purposes:

      1. ensuring the security and smooth running of the Site;

      2. combating fraudulent use of the Site;

      3. management of access to and the use of certain Services;

      4. building files of members registered for the Services;

      5. sending newsletters, referrals and promotional messages on condition that the User checks the appropriate box to agree to this when registering for the Services;

      6. drawing up statistics and measuring the frequentation of the Services;

      7. organising games-contests, lotteries and all promotional operations, excluding online gambling and betting that are subject to certification from the Online Games Regulatory Authority;

      8. management of User opinions and surveys on the Services or contents of the Site;

      9. monitoring operations carried out by a User by means of the Site;

      10. the personalisation of the adverts shown to the Users of the Site so that they match their centres of interest.

 

When Data is collected, the User shall be informed whether filling in certain items is mandatory or optional. The Data identified with an asterisk on the registration forms is mandatory. Failing this, access to the Services and their use by the User may be restricted.

 

3) RECIPIENTSOF THEDATA COLLECTed

The Database compiled when registering for the Services is strictly confidential. The Publisher undertakes to exercise every care and implement the appropriate organisational and technical measures to preserve the security, integrity and confidentiality of the Data and, in particular, to prevent it from being distorted, damaged or accessed by unauthorised third parties.

 

      1. Data transferred to the authorities and/or public bodies:

In compliance with the regulations in force, the Data may be transmitted to the competent authorities on request, including to public organisations, exclusively to meet the legal obligations and those of legal officials, ministerial officers and the bodies responsible for the collection of receivables.

 

      1. Data transferred to third parties:

With the prior consent of the User, the Data may be used by the Publisher, their sub-contractors, affiliates and/or commercial partners:

        • The personnel of and the departments in charge of auditing the Publisher (the statutory auditor in particular) and the sub-contractors will have access to the Data collected within the scope of the use of the Site.

        • By checking the box “I wish to receive special offers and shopping advice from LeGuide.com by email”, the User agrees to allow their reporting Data be used by all the companies in the LeGuide.com group(which means the group of companies controlled directly or indirectly by Kelkoo.com Limited, a company governed by English law, headquartered at 6th Floor, Portland House, London, SW1E 5BH, United Kingdom, in the sense of article L. 233-3 of the French Code of Commerce), comprising the Publisher, to inform them of the latest commercial offers or products or services similar to those for which the User has registered.

      1.  

c) Social networks:

If the User has an account on any social network sites and accesses the Site without first being registered for the Services, the Publisher may receive information from such social networks to facilitate the creation of an account on the Site.

When the User uses a Service via a social network site, the User allows the Publisher to access information they provided to the social network site, including surname and first name, profile photo and data relative to the use of this Service. By accessing a Service via a social network site, the User authorises the Publisher to collect, store and use any information the User authorised the social network site to supply the Publisher with.

 

4) RIGHTS OF THE USER RELATIVE TO PERSONAL DATA

In compliance with the legislation in force, Users have the following rights:

  1. Right of access: this right comprises the possibility of obtaining confirmation that personal data concerning the User is being processed and, where relevant, of obtaining information concerning (i) the purpose of the processing, (ii) the categories of Data processed, (iii) the recipients or categories of recipients of the Data, (iv) the conservation time envisaged or the criteria used to determine this, (v) the right of to request that personal data be corrected or deleted, or a limitation to the processing of this data, or the right to oppose this processing, (vi) the right to make a complaint to a supervisory authority, (vii) if the Data was not collected from the User, any information available about the source and, if applicable, (viii) the existence of an automated decision, including profiling, and the relevant information concerning the underlying rationale, as well as the importance and the expected consequences of this treatment for the User.

 

  1. Right to correct: this right comprises the possibility of having any errors in the personal Data concerning the User corrected in a timely manner.


 

  1. Right to delete: this right comprises the possibility of having any personal Data concerning the User deleted in a timely manner when one of the following grounds applies: (i) Data no longer required for the purposes for which it was collected or processed, (ii) The User has withdrawn consent and there is no other legal basis for the processing, (iii) The User has imposed their right of opposition and there is no compelling legitimate reason for the processing, (iv) the Data has been subject to unlawful processing, (v) the Data must be deleted pursuant to a legal obligation.


 

  1. Right to limitation: this right comprises the possibility for the User to request the restriction of the processing of Data in the following cases: (i) when the accuracy of the Data is contested by the User, the restriction could be used to allow the Publisher time to check the accuracy of the Data, (ii) the processing is unlawful and the User is opposed to deleting the Data and demands instead a restriction on the use of said Data, (iii) the Data is no longer necessary for the purpose for which it was collected but is required by the User for the establishment, exercise or defence of legal claims, (iv) when the User has exercised their right to oppose, the limitation could provide a period allowing a check on whether the legitimate grounds pursued by the Publisher should prevail over those of the User. The user who has obtained a limitation of the processing shall be informed before the limitation is removed.


 

  1. Right of refusal: this right comprises the right to refuse at any time, for reasons related to the User’s specific situation, processing of Data necessary for carrying out a mission in the public interest or pertaining to the exercise of public authority or if the processing is necessary for the purposes of the legitimate interests pursued by the Publisher or a third party and it cannot be demonstrated that there are compelling, legitimate grounds for the processing that prevail over the interests and the rights and liberties of the User concerned. When the Data is used for the purposes of prospecting, the User may refuse at any time the processing of Data for such purposes.


 

  1. Right to the portability of the Data: this right comprises the possibility, for a User, of receiving the Data they provided, in a structured format, commonly used and machine readable and the possibility of asking for this Data to be transmitted to another controller when the processing in question was based on the consent of the User or was necessary for fulfilling an agreement to which the User was a party. The exercise of this right is understood without prejudice to the right to delete referred to above.

The rights can be exercised at any time by contacting the Data Protection Officer of LeGuide.com, whose contact details are given below: dpo@group.leguide.com

Any requests to correct, delete restrict or oppose on the part of the User shall be forwarded by the Publisher to any third parties having received communication of the User’s Data (e.g.: third party referencing operators and/or search engines), unless such forwarding is impossible or requires disproportionate efforts.

Any requests from a User aimed at exercising one of the above-mentioned rights shall be processed in the month following the request or, if necessary, depending on the number and the complexity of the request, within three months of said request, the User should then be informed of this time period and of the reasons for it.

Any requests from a User aimed at exercising one of the above-mentioned rights carried out through electronic channels shall be handled by electronic channels, unless otherwise stipulated by the User.

Communication in relation to a User request to exercise one of the above-mentioned rights shall be carried out free of charge. In the case of an obviously unfounded, excessive or repetitive request, it shall be possible for the Publisher to demand the payment of management fees or to refuse to grant the User request.

In the case of doubt about the identity of the User, the Publisher reserves the possibility of asking for additional information.

 

5) DATA RETENTION AND STORAGE

User Data will not be kept for longer than is strictly necessary for the intended purposes, as stated in this Charter, in compliance with the applicable regulations. User Data is deleted when the retention periods expire. Nonetheless, the Data may be stored beyond the initially scheduled periods for the needs of investigating, establishing and prosecuting criminal infringements for the sole purpose of being able, as required, to make such Data available to the legal authorities. Storage implies that the Data can no longer be consulted on line but will be extracted and retained on an autonomous, secure medium.

 

6) SECURITY

The Publisher takes adequate measures on a technology and organisational level to prohibit unauthorised access or the disclosure of User Data. However, the Publisher cannot guarantee the elimination of all risks of abusive use of the Data. It is important that the User keeps confidential their logon identifiers to prevent the unlawful use of their account.

The User is informed and accepts that Public Data items may be published centrally when the User accesses their account.

The Publisher cannot guarantee the confidentiality or deletion of the Public Data in the public parts of the Services. In addition, the Publisher cannot be held liable for spam sent to the User of the Services who decides voluntarily and spontaneously to publish their email address online.

 

  1. II. COOKIES

  2.  

A cookie is a text file that is stored on your device when you use a Service with browser software. A Cookie, while valid, allows the identification of the device concerned each time it accesses digital content that includes Cookies from the same source.

The User is informed that, when connecting to the Site and using the Services, Cookies are installed on their device (computer, tablet, smartphone, etc.) for the smooth running of the Services, or on their browser, subject to of the choice expressed by the User concerning Cookies, which can be changed at any time.

 

1) what are THE TYPES of COOKIES?

In order to inform the User optimally about Cookies, they can be grouped into 4 categories: (a) Site browsing Cookies, (b) Audience measurement Cookies, (c) advertising Cookies, (d) Cookies for targeting behaviour.

 

a. Site browsing Cookies


Site browsing Cookies are used to improve the performance of the Services to provide the User with a better use of the Site. These Cookies can be placed on the User’s device without informing the User or seeking their prior consent.

 

More precisely, these browser Cookies are used, in particular, to:

 

      • adapt the presentation of the Site to the device display preferences (language used, resolution, operating system, etc.) when Users visit the Site, according to the hardware and software they use for displaying or reading;

      • memorise information relative to the form the User filled in on the Site or information the User chose on the Site;

      • offer the User access to their account or to any other reserved space thanks to their login details;

      • implement security measures, for example when the User is asked to log on again to content or a Service after a certain time period has elapsed.

 

b. Audience measurement Cookies


Audience measurement Cookies help to establish statistics and to determine the volumes of frequentation and use of the various components of the Site (rubrics and contents visited, paths), thereby allowing the Publisher to improve the relevance and the ergonomics of the Services.

 

c. Advertising Cookies


Advertising Cookies are used to determine in real time which advertising to display depending on the User’s recent Site browsing history to limit the number of times the User sees an advert and to help measure the impact of an advertising campaign.

 

d. Cookies for targeting behaviour


Cookies for targeting behaviour are used to identify the Site information which could be of most interest to the User, contribute to improving browsing experience and making it more interesting.

To the extent that the User provided the Publisher with Data concerning them, in particular by registering for the Services, the Publisher may, subject to the choice of the User, associate browsing information processed by the Publisher’s Cookies with the User Data to send, for example, electronic prospecting or display personalised ads on their device, in the advertising spaces containing Cookies.

The User may at any time ask not to receive advertising or prospecting adapted to the browser information on their device, by contacting the Publisher directly and free of charge, or by means of the unsubscribe link included on any prospecting materials the Publisher may send by email. If the User decided to refuse behavioural advertising, this does not mean they will not receive any Internet advertising. This merely means that the advertising displayed on the Site will not match their centres of interest or preferences on the User’s Internet browser.

 

Should the Publisher plan to obtain from a third party User browser information that the Publisher may associate with the Data provided by the User, the Publisher shall first ask for the User’s explicit consent before proceeding to such an association and send targeted advertising or offers.

 

2) WHICH TYPE OF COOKIES DO WE USE?

 

We use the following types of Cookies:

THIRD PARTY COOKIES

Cookie

Type

Purpose

Additional information

Google Analytics

Performance

Audience measurement

https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

AdWords Remarketing

Targeting

Personalisation of advertising content

https://support.google.com/adwords/answer/2407785?hl=fr

Captify

Targeting

Personalisation of advertising content

http://www.captify.co.uk/privacy-policy/

Exelate

Targeting

Personalisation of advertising content

http://www.exelate.com/privacy/opt-in-opt-out/

RTB House

Targeting

Personalisation of advertising content

https://www.rtbhouse.com/privacy/

 

LEGUIDE COOKIES

Cookie

Type

Purpose

Kept for

VisitorId

Performance

Identification of the User and personalisation of browsing

30 days

VisitorUid

Performance

Identification of the User and personalisation of browsing

12 months

VisitorId_Session

Performance

Audience measurement

30 minutes

VisitorId_Month

Performance

Audience measurement

30 days

KelkooID

Performance

Identification of the User and personalisation of browsing

12 months

CK_SLKW3

Performance

Identification of the User and personalisation of browsing

30 days

CK_PUBLISHER

Performance

Identification of the User and personalisation of browsing

30 days

CK_SB

Performance

Identification of the User and personalisation of browsing

13 months

CK_ACCEPT

Function

Personalisation of browsing and display of Cookie banner

396 days

lastTrafficSource

Performance

Identification of the User and personalisation of browsing

30 days

CK_DISPLAY_MODE

Function

Personalisation of browsing and identification of the User

The duration of the User browser session

CK_RDC_COUNTRY_LABEL

Function

Personalisation of browsing and identification of the User

30 days

CK_RDC_COUNTRY_CODE

Function

Personalisation of browsing and identification of the User

30 days

CK_RDC_ID_ZONE

Function

Personalisation of browsing and identification of the User

30 days

CK_BK_{clic_id}

Function

Personalisation of browsing

1 hour


 

 

3) HOW CAN THE USER MANAGE COOKIES?

 

The User is first of all informed that the Publisher’s partners and other third parties may place Cookies on the Site. Only the domain placing the Cookie can read or edit the information it contains and the Publisher has no access to or control of Cookies placed by third parties. The placing and use of Cookies by third parties are subject to the privacy policies of these third parties in addition to the provisions of this Charter. Consequently, the User is invited to visit the websites of these third parties for more information about the Cookies they use and how the User can manage them.

 

  1. Agreement on Cookies

 

Any one of the following actions completed by the User shall be considered as giving consent to the use and placing of Cookies:

 

      • By clicking on the “X” icon on the information banner visible on first connection to the Site to close the banner;

      • By continuing to browse, that is to say when the User has clicked on an item in the Site (picture, link, “find” button, etc.) or has visited another page of the Site.

 

If the User agrees via heir browser software to the placing of Cookies on their device, the Cookies included in the pages and contents they have browsed may be stored temporarily in a dedicated space on the device. They can be read only by the domain that placed them.

 

The User’s consent is only valid for a period of thirteen (13) months from the first placement in the User’s device, following the User’s consent.

 

  1. Refusing Cookies

 

If the User refuses the placing of Cookies on their device or browser, or if they delete the ones saved there, they should know that their browsing and experience of the Site may be limited. This may also be the case if the Publisher or one of their service providers does not recognise, for the purposes of technical compatibility, the type of browser used by the device, the language and display settings or the country from which the device is connected to the Internet.

In any case, the Publisher declines all responsibility regarding the consequences related to the degraded operation of the Services resulting from the (i) refusal of Cookies by the User and/or (ii) the impossibility for the Publisher to save or consult the Cookies necessary for their operation due to the User’s choice.

 

  1. Configuration of the browser software

 

The User can configure their browser to allow Cookies to be placed on their device or, on the contrary, to be rejected, either systematically, or depending on the identity of the domain placing them. The User can also configure their browser to accept or refuse Cookies proposed intermittently, before a Cookie is placed on their device.

 

For the management of Cookies and User choices, the configuration of each browser is different. This is described in the help menu of the browser, which shows how to change your preferences in terms of Cookies. You will find below the link to the help pages of certain browsers:


For Internet Explorer™ 

For Safari

For Chrome

For Firefox

For Opera

 

At any time, the User may choose to express and amend their preferences in terms of Cookies.

 

  1. Other means of contesting

 

For more information on Cookies, the User is invited to refer to the recommendations of the Information Commissioner’s Office (ICO): https://ico.org.uk.

 

Lastly, the User can visit the website Youronlinechoices, proposed by the digital advertising professionals grouped together under the EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France. The User can find out which companies are registered on this platform which offers the possibility of refusing or accepting the Cookies used by these firms to adapt the advertising displayed, with respect to the user’s recent browsing history:

http://www.youronlinechoices.com/fr/controler-ses-cookies/.

 

This Charter on data privacy and cookies was last updated on 20 June 2018.