Privacy Policy

1. Purpose

When using the sites accessible at the addresses People Power Inclusion (the “Site(s)”), People Power Inclusion, whose contact details are detailed in Article 2 below, is led to collect personal data from Users and Members (the “Personal Data”).

The purpose of this personal data protection charter (hereinafter the “Charter”) is to inform Users and Members of the use made by People Power Inclusion of Personal Data. This use is made in compliance with the Law n° 78-17 of 6 January 1978 relating to data processing, files and freedoms, amended by Law n°2004-801 of 6 August 2004 and by Law n° 2018-493 of 20 June 2018 (the “Data Protection Law”) and, the Directive of 12 July 2002 amended by Directive 2009/136/EC (the “ePrivacy Directive”) and, the Regulation (EU) 20

2. Definitions

The terms “personal data” (“Personal Data”), “Processor/Processing”, “Processor”, “Sub-processor”, “Recipient(s)”, “Consent”, have the same meaning as set out in Article 4 of the GDPR.

“Member(s)” means any natural person who has a Member Account allowing him/her to access the features of the Site or Services of People Power Inclusion;

“User(s)” means any natural person accessing the Site(s) and Services without having created a Member Account, and using only certain features of the Site(s) or Services of People Power Inclusion;

“Third Party” means any natural or legal person who is a third party to People Power Inclusion, a User or a Member;

“Services” means all or part of the services offered by People Power Inclusion on its site;

“Site(s)” means the website(s) published by the Services available at People Power Inclusion or any other site related to the Services.

3. Purposes and controller of personal data

We attach the greatest importance to the respect of your privacy and the protection of your Personal Data. This is why the {{entity}} processes your Personal Data, in compliance with the Applicable Regulations, for the following purposes :

to contact Users and to manage the relationship with Users and Members ;
to inform Users and Members of news, events and other activities of People Power Inclusion ;
to offer Services in relation to the activities of the {{entity}} ;
to consult and keep information relating to navigation on the Sites which may be recorded in “cookies” files (defined in Article 9 below).

For these purposes only, the Data Controller is {{responsible_address}}, whose contact details can be found in Article 10 below.

4. What Personal Data is collected, for what purposes?

When collecting Personal Data, the User or Member will be informed whether certain Personal Data must be filled in or whether they are optional. Failure to provide the Personal Information that must be collected will prevent access to certain features of the Services. The People Power Inclusion may collect the following categories of Personal Data:

4.1 Concerning the users

The name, first name and email address in order to receive the newsletter of People Power Inclusion. The declaration of Consent involves the voluntary transmission of this information by the User in each of the fields provided for this purpose in the Newsletter Sending Form. The User has the possibility, at any time, to refuse the sending of newsletters by the corresponding link in the newsletter or by sending a message. The email address will then be deleted from the People Power Inclusion distribution list.
The name, first name and e-mail address in order to get in touch with a contact person of People Power Inclusion. The declaration of Consent involves the voluntary transmission of this information by the User in each of the fields provided for this purpose in the Contact Form.
Any other information constituting Personal Data within the meaning of the Applicable Regulations voluntarily provided in the “Leave your message” part of the Contact Form, the unsolicited application form and by any other appropriate means.
Navigation data as detailed in Article 9 below.

4.2 Concerning members

The identification data collected when creating a Member Account and in particular, surnames, first names, e-mail addresses and encrypted password.
The information constituting Personal Data within the meaning of the Applicable Regulations voluntarily filled in by the Member in the Account Management Form, and in particular the telephone number, the Facebook, Twitter or LinkedIn URL, the job title, and the centres of interest, making it possible to better know the Member.
The name, first name and email address of the Member in order to receive the People Power Inclusion newsletter. The declaration of Consent involves the voluntary transmission of this information by the Member in each of the fields provided for this purpose in the Newsletter Sending Form. The Member has the possibility, at any time, to refuse the sending of newsletters by the corresponding link in the newsletter or by sending a message. The e-mail address will then be deleted from the People Power Inclusion distribution list.
The name, first name and e-mail address in order to get in touch with a contact person of People Power Inclusion. The declaration of Consent involves the voluntary transmission of this information by the Member in each of the fields provided for this purpose in the Contact Form.
Any other information constituting Personal Data within the meaning of the Applicable Regulations voluntarily provided in the “Leave your message” part of the Contact Form or the spontaneous application form and by any other appropriate means.
Navigation data as detailed in Article 9 below.

5. Recipients of Personal Data

The database of Personal Data constituted at the time of your use of the Services is strictly confidential. The {{entity}} undertakes to take all useful precautions, organisational and technical measures appropriate to preserve the security, integrity and confidentiality of the Personal Data, and in particular to prevent them from being distorted, damaged or accessed by unauthorised Third Parties.

5.1 Data transferred to public authorities and/or bodies

In accordance with the Applicable Regulations, Personal Data may be transferred to the competent authorities upon request and in particular to public bodies, exclusively to meet legal obligations, judicial officers, ministerial officers and bodies responsible for collecting debts.

5.2 Data Accessible to Third Parties

The Personal Data may be used by the {{entities}}, its Subcontractors, the joint Processors, its affiliates and/or, if applicable, its partners, for the purposes described in Article 3 above.

The authorized personnel of People Power Inclusion by virtue of their functions, the services in charge of control (auditor in particular) and the subcontractors of People Power Inclusion will have access to the Personal Data collected in the context of the use of the Services;
Social networks: if the User or Member has an account on social network sites and accesses the Services, these may include plugins such as “Like” buttons or sharing or redirection buttons, allowing the publication of content of the Services on social networks. Where applicable, the social networks concerned may receive information relating to the use of the Services by the User or Member.

5.3 Transfers Outside of the European Union

The Personal Data of the User and the Member may be processed outside the European Union, including via remote access. The {{entity}} undertakes not to carry out any transfer of Personal Data outside the European Union without implementing appropriate safeguards in accordance with the Applicable Regulations.

6. User And Member Rights

Subject to an express request and proof of their identity to People Power Inclusion, the User and the Member have a right of access, rectification and opposition on their Personal Data, as well as a right to erasure, under the conditions of the Applicable Regulations, by contacting People Power Inclusion at the postal or electronic address mentioned in Article 10 below.

In case of exercise of the right to object, the People Power Inclusion will cease the Processing of the Personal Data, except in case of legitimate and compelling reason(s) for the Processing, or to ensure the establishment, exercise or defence of its legal rights, in accordance with the Applicable Regulation. Where applicable, the {{entity}} shall inform the User or Member of the reasons why the rights exercised cannot be satisfied in whole or in part.

Subject to an express request and proof of identity to People Power Inclusion, the User and the Member also have the right to recover their Personal Data in a structured, commonly used and machine-readable format, in order to transmit them to another Controller.

The User and the Member have the right to provide People Power Inclusion with directives concerning the fate of their Personal Data after their death.

Where applicable, the People Power Inclusion shall inform the User or Member of the reasons why the rights exercised cannot be satisfied in whole or in part.

7. Duration of Retention of Personal Data

The Personal Data of Users and Members are not kept beyond the period strictly necessary for the purposes set out in Article 3 above, in accordance with the Applicable Regulations. In particular :

Personal Data collected to manage requests to object to the Processing are stored for a maximum of 5 (five) years from the closure of the objection request;
Personal Data Processed to manage requests for access and rectification of Personal Data are stored for a maximum period of 5 (five) years from the closing of the requests;
The Personal Data collected for the purpose of sending information or offers (in particular by sending newsletters) are stored for a maximum period of 3 (three) years after the last contact between People Power Inclusion and the User or the Member;
The Personal Data relating to the management of interactions with People Power Inclusion’s interlocutors (in particular through the “Contact” section) are kept for a maximum period of 3 (three) years after the last interaction initiated by the User. The Personal Data relating to the creation of the Member Account are kept for a maximum period of 3 (three) years from the termination of the contract.

Personal Data may be archived beyond the periods described above insofar as they are necessary for the purposes of research, the establishment and prosecution of criminal offences, with the sole aim of making the Personal Data available to the judicial authorities, if necessary, or for other storage obligations, in particular for accounting or tax purposes. Archiving implies that this Personal Data will be subject to access restrictions and will be stored on an autonomous and secure medium.

8. Security

In accordance with the Applicable Regulations, People Power Inclusion Processes Personal Data in a secure and confidential manner.

In particular, People Power Inclusion implements all technical and organisational measures necessary to guarantee the security and confidentiality of the Personal Data collected and Processed, and in particular to prevent them from being distorted, damaged or communicated to unauthorised Third Parties, by ensuring a level of security adapted to the risks linked to the Processing and to the nature of the Personal Data to be protected, having regard to the level of technology and the cost of implementation.

However, People Power Inclusion cannot guarantee the confidentiality of the Personal Data made public by the User and the Member in the public parts of the Site and the Services.

The Site may include links to external websites or sources. The User and the Member acknowledge that the Charter only applies to the Services and the use of the Sites, and does not cover in any way the information collected and/or Processed on the external sites or sources, the link of which appears on the Site. Consequently, People Power Inclusion cannot be held responsible for the practices of these external sites or sources with regard to the collection and Processing of Personal Data, which are governed, where applicable, by the personal data charters specific to each of these external sites or sources.

9. Cookie Policy

9.1 What is a Cookie ?

Among the Personal Data, People Power Inclusion may collect data resulting from the deposit of cookies.

A cookie is a small text, image or software file that is placed and stored on the User’s or Associate Member’s computer or smartphone, as well as on any device that allows them to browse the Internet (“Terminal”).

Very useful, cookies allow a website to recognise the User or Member, to indicate their visit to a particular page and thus to provide them with an additional service: improving their browsing comfort, securing their connection or adapting the content of a page to their interests.

The information recorded by the cookies, for a limited period of validity, concerns in particular the pages visited, the advertisements on which the User or Member has clicked, the type of browser they use, their IP address, the information they have entered on the Services (in order to avoid re-entering it).

Cookies are not active files, and therefore cannot host viruses. For more information, please visit www.allaboutcookies.org.

9.2 What is the Purpose of the Cookies Issued on the Sites ?

Only the issuer of a cookie is likely to read or modify the information contained in it.

Cookies are used for the purposes described below, subject to your choices, which you may express and modify at any time via the settings of the browser software used when browsing the Sites (hereinafter “Cookies”).

9.2.1 Browsing Cookies

Browsing Cookies allow us to improve the performance of People Power Inclusion in order to provide a better use of the Sites. These Cookies do not require the information of the User and the Member, nor their prior agreement to be deposited on the Terminal.

Browsing Cookies allow :

· to adapt the presentation of the Sites to the display preferences of the Terminal (for example, language used, display resolution, operating system used, etc.) during Users’ visits to the Sites, according to the hardware and the display or reading software that the Terminal contains;

· to memorise the user preferences, display settings and readers that the User and the Member use in order to facilitate their navigation during their next visit to the Sites. In particular, they allow access to a reserved area subject to an identifier or a password;

· to memorise the information entered on certain forms on the Site in order to avoid having to fill them in again during their next visit.

9.2.2 Statistical Cookies

In order to adapt the Sites to the needs of the User and the Member, People Power Inclusion measures the number of visits, the number of pages consulted as well as the activity of the User and the Member on the Sites and their frequency of return. These Cookies make it possible to establish statistics for the analysis of the frequentation from which the contents of the Sites are improved according to the success of such or such page with the Users or the Members.

The results of these analyses are processed anonymously and for statistical purposes only.

Cookie Sender	Cookie Name	Finality of the Cookie	Opt-out (refer to opt-out procedures if applicable)	Lifetime of the Cookie
	MATOMO_SESSID	It is important to note that it does not contain any personally identifiable data and is considered an “Essential”		14 days
	_pk_id	This cookie is used to store some details about the user such as the unique visitor ID		13 months
	_pk_ses	This cookie is short-lived and is used to temporarily store data about the visit		30 minutes

9.3 Duration of Validity of Cookies

The Cookies issued on the Sites are session Cookies (the duration of which is limited to the time of a connection to the Sites) and persistent Cookies (the duration of which, however limited, is greater than the duration of a connection).

Session Cookies are only active for the time of the visit and are deleted when the User or Member closes his or her browser. Persistent Cookies remain stored on the hard disk of the User’s or Member’s Terminal once the browser is closed.

In accordance with the Applicable Regulations and the recommendations of the Commission Nationale Informatique et Libertés (“CNIL”), Cookies are kept for a maximum period of 13 (thirteen) months after their first deposit. At the end of this period, the User’s or Member’s Consent must be collected again for the collection of Cookies subject to Consent.

9.4 Your Choice regarding Cookies

All the rights recognised in Article 6 above are also applicable to the User or Member.

Several possibilities are offered to them to manage Cookies. The User and the Member understand that Cookies improve the comfort of navigation on the Sites and are essential to access certain secure areas. Any parameter setting that the User or Member may undertake may modify their navigation on the Sites and their conditions of access to certain services requiring the use of Cookies. People Power Inclusion cannot be held responsible for the consequences of a less efficient functioning of the Sites due to the impossibility of installing or reading Cookies necessary for their proper functioning, once the User or Member has rejected or deleted them.

Users and Members may configure their browsing software so that Cookies are saved in their Terminal or, on the contrary, rejected, either systematically or according to their sender. Users and Members may also configure their browser software so that acceptance or rejection of Cookies is offered to them from time to time, before a Cookie is likely to be recorded on their Terminal.

The help menu or the dedicated section of your browser will enable you to know how to express or modify your preferences with regard to Cookies:

· For Internet Explorer™ :

http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

· For Safari™ :

https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

· For Chrome™ :

http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

· For Firefox™ :

http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

· For Opera™ :

https://help.opera.com/en/latest/web-preferences/#cookies

· For iOS :

https://support.apple.com/fr-fr/HT201265

· For Android :

https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DAndroid&hl=fr

· For Blackberry :

https://global.blackberry.com/fr/legal/cookies

· For Windows Phone :

https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies

For a better knowledge and control of Cookies of any origin and not only those of our Site, the User and the Members are invited to consult the site Youronlinechoices, published by the Interactive Advertising Bureau France (IAB) in order to know the companies registered with this platform and which offer the possibility of refusing or accepting the Cookies used by these companies to adapt the browsing information and the advertisements likely to be displayed on the Terminal http://www.youronlinechoices.com/be-fr/controler-ses-cookies

10. CONTACT AND COMPLAINTS

For any request or in case of dispute between People Power Inclusion and the User and/or the Member, concerning the Processing of their Personal Data, the latter may address their request or complaint to People Power Inclusion by contacting it at the following postal address: {{responsible_address}} or at the following e-mail address {{responsible_mail}}

{{entity}} will endeavour to find a satisfactory solution to ensure compliance with the Applicable Regulations. 15 rue Fontaine au Roi 75011 Paris ou à l’adresse de courrier électronique suivante contact-rgpd.action-internationale@groupe-sos.org

In the absence of a response from People Power Inclusion or if the dispute persists despite the group’s proposal, the User and/or the Member may lodge a complaint with the CNIL or the supervisory authority of the Member State of the European Union in which the User or the Member usually resides and to mandate an association or organisation mentioned in IV of article 43 ter of the amended law n°78-17 of 6 January 1978.