ARTICLE 1: PREAMBLE
• How the user’s personal data is collected and processed. All data likely to identify a user must be considered as personal data. This includes the user’s first name and last name, age, postal address, email address, location or IP address;
• What are the user’s rights in relation to this data;
• Who is responsible for processing the personal data collected and processed;
• To whom this data is passed on;
• Alternatively, the site’s policy in relation to “cookies” files.
ARTICLE 2: GENERAL DATA COLLECTION AND PROCESSING PRINCIPLE
In accordance with the provisions of article 5 of the EU General Data Protection Regulation 2016/679, the collection and processing of site user data respect the following principles:
• Legality, good faith and transparency: data may only be collected and processed with the consent of the user who owns the data. Each time personal data is collected, the user will be informed that their data is being collected, and the purpose for the data collected;
• Limited purposes: the data is collected and processed to meet one or more objectives as determined in the General Usage Conditions;
• Minimization of data collection and processing: only the data needed to carry out the site’s objectives is collected;
• Reduced data conservation over time: the data is kept for a limited period, of which the user is informed. Conservation of data is reduced over time if the storage period cannot be communicated to the user;
• Integrity and confidentiality of the data collected and processed: the data processing manager undertakes to guarantee the integrity and confidentiality of the data collected.
In order to be legal, and in accordance with the requirements of article 6 of the EU General Data Protection Regulation 2016/679, personal data may only be collected and processed if at least one of the conditions below are respected:
• The user has given express consent for the processing;
• The processing is necessary to carry out a contract;
• The processing responds to a legal obligation;
• The processing can be explained by a need related to saving the vital interests of the person concerned or another individual;
• The processing can be explained by a need related to carrying out a public interest mission or one that falls within the scope of public authority;
• The processing and collection of personal data are necessary for the legitimate and private interests of the person in charge of processing it or a third party.
ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED WHILE BROWSING THE SITE
A. DATA COLLECTED AND PROCESSED AND COLLECTION METHOD
The personal data collected on the site patrickrubinstein.com are as follow:
• First name
• Last name
• Telephone number
• IP address
This data is collected when the user performs one of the following operations on the site:
• When the user visits the On View tab
• When the user sends a message
The data processing manager will keep the data collected in the site’s information technology systems and under reasonable security conditions safeguard the data collected for a period of: 5 years.
The data is collected and processed for the following purposes:
The IP addresses are collected and registered to provide better target advertisements
B. DATA TRANSMISSION TO THIRD PARTIES
The personal data collected by the site is not transmitted to any third parties, and is only processed by the site’s publisher.
C. DATA HOSTING
The site patrickrubinstein.com is hosted by: OVH, whose head office is located at the address below:
2 rue Kellermann – 59100 Roubaix – France
The hosting company may be contacted on the following telephone number: 1007
The data collected and processed by the site is hosted and processed exclusively in France.
ARTICLE 4: DATA PROCESSING MANAGER
A. THE DATA PROCESSING MANAGER
The data processing manager responsible for the personal data is: Patrick Rubinstein. He may be contacted as follows:
The person in charge of the data collected may be contacted by email at the address:
The data processing manager is in charge of determining the end purposes and the resources used to process personal data.
B. DATA PROCESSING MANAGER’S OBLIGATIONS
The data processing manager undertakes to protect the personal data collected, to not pass it onto any third parties without the user being informed of it, and to respect the end purposes for which this data is collected.
In addition, the data processing manager undertakes to notify the user if the data is rectified or deleted, unless this generates disproportionate formalities, costs and procedures.
If the integrity, confidentiality or security of the user’s personal data is compromised, the data processing manager undertakes to inform the user by all means.
ARTICLE 5: USER RIGHTS
In accordance with the regulation concerning personal data processing, the user has the rights listed below.
For the data processing manager to be able to meet their request, the user must communicate: their first and last name and email address, and if relevant, their account, personal space or subscriber number.
The data processing manager is obliged to respond to the user within a maximum of 30 (thirty) days.
A. PRESENTATION OF THE USER DATA COLLECTION AND PROCESSING RIGHTS
a. Rights to access, rectification and erasure
The user may review, update, modify or request the deletion of the data that relates to them by respecting the procedure below:
The user must send an email to the data processing manager in charge of the personal data processing, by specifying the subject of the request, to the contact email address provided above.
If the user is in possession of an account related to the site, they have the right to request for account deletion by following the procedure below:
The user must send an email to the data processing manager, specifying their email address. The deletion request will be processed within 10 business days.
b. Right to data portability
The user has the right to request the portability of their personal data, held by the site, to another site, by conforming to the procedure below:
The user must make a request to the data processing manager for the portability of their personal data, by sending an email to the address provided above.
c. Right to limit and oppose the processing of the data
The user has the right to request the limitation or oppose the processing of their data by the site, without the site being able to refuse this, unless it can demonstrate legitimate and compelling reasons that may prevail over the user’s interests and rights and freedoms.
To request the limitation of their data processing or to formulate the opposition to their data processing, the user must follow the procedure below:
The user must make a request to the data processing manager to limit the processing of their personal data, by sending an email to the address provided above.
d. Right to not be the subject of a decision based exclusively on an automated process
In accordance with the provisions of the EU General Data Protection Regulation 2016/679, the user has the right to not be the subject of a decision based exclusively on an automated process if the decision produces legal effects in relation to them, or affects them significantly in a similar way.
e. Right to determine how data is used after their death
The user is reminded that they may arrange what is to become of their data collected and processed if they die, in accordance with the law No. 2016-1321 of October 7th 2016.
f. Right to contact the relevant inspection authority
If the data processing manager decides not to respond to the user’s request, and the user wishes to contest this decision, or if they think that one of the rights listed above has been infringed, they are entitled to contact the CNIL (Commission Nationale de l’Informatique et des Libertés – National Commission on Information Technology and Liberties in France, https://www.cnil.fr) or any competent judge.
B. PERSONAL DATA OF MINORS
In accordance with the provisions of article 8 of the EU General Data Protection Regulation 2016/679, and the Information Technology and Liberties law, only minors aged 15 years and over may consent to the processing of their personal data.
If the user is a minor under 15 years of age, the consent of a legal representative will be required for their personal data to be collected and processed.
The site’s publisher reserves the right to verify by all means that the user is over 15 years of age, or that the user has obtained the consent of a legal representative before browsing the site.
The site’s publisher reserves the right to modify it to guarantee its compliance with current law.