Personal data and personal data processing: What is it about 

Personal Data is information and data that identifies or makes identifiable a natural person (name, email address, phone number or IP address, etc.) and processed electronically or not.

The processing of Personal Data refers to any operation or set of operations carried out or not by means of automated processes and applied to data or sets of personal data such as collection, recording, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, deletion or destruction.

Who is the data controller?

The company SKEZI (hereinafter "SKEZI") acts as a controller, in the sense of the applicable regulations, when it processes the Personal Data of the users.  

As a data controller, SKEZI ensures a high level of protection of the Personal Data of the persons concerned during all the stages of their processing (collection, storage, destruction...).

SKEZI commits itself to respect the legislation and regulations in force concerning the protection of Personal Data and more particularly:

- Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data (GDPR) 
- the French Data Protection Act and Ordinance no. 2018-1125 of December 12, 2018 on the protection of personal data, amending Act 78-17 of January 6, 1978 on Data Processing, Data Files and Individual Liberties and various provisions concerning the protection of personal data

What personal data?

SKEZI does not collect any sensitive data on its website.  
SKEZI processes the following Personal Data in particular:
- Data relating to the identity and contact information of users (name, first name, address and email);
- Cookie data for statistical purposes in order to improve the ergonomics of the site and to measure the number of pages viewed, the number of visits, as well as the activity and the user's path on the site. This data may be processed, in particular, on the occasion of:
- The use of the website
- When these Personal Data are collected, SKEZI informs the user about the compulsory or optional character of the requested Personal Data, the envisaged use and the consequences of a lack of information.

Why collect users' personal data?

The Personal Data communicated by the user to SKEZI are subject to computer processing and are kept and used by SKEZI for the following purposes:
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- to allow navigation on the Site and the management and traceability of the services ordered by the user: connection data and use of the Site, billing, order history, etc.
- to prevent and fight against computer fraud (spamming, hacking...): computer equipment used for navigation, IP address, password (hashed)
- to improve navigation on the Site: connection and usage data
- to conduct optional satisfaction surveys on SKEZI: email address
- to conduct communication campaigns (sms, email): phone number, email address
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SKEZI does not sell your personal data which are only used for statistical and analysis purposes.

Under what legal framework is user data processed?

SKEZI processes users' personal data on the following legal grounds:  
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- Meet its obligations to users on the basis of their consent (Article 6(a) of the GDPR);
- Meet some of its legitimate interests(Article 6 f) of the GDPR). 
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In all cases where the user's consent is required, the collection of this consent is express (opt-in box) and specific. The user can then withdraw his consent at any time.

For how long is the data kept?

SKEZI will keep the user's Personal Data only for a limited period of time, determined and according to the nature of the data in question and the processing concerned.

Who are Skezi's subcontractors?

Within the framework of its activity, SKEZI may have to call upon subcontractors for whom it undertakes to maintain an adequate level of protection. SKEZI prefers to store your data in the European territory through subcontractors who offer appropriate guarantees.‍

International transfers

SKEZI shall not process, host or transfer the Information collected on its Customers to a country located outside the European Union or recognized as "not adequate" by the European Commission without informing the customer in advance. However, SKEZI remains free to choose its technical and commercial subcontractors provided that they present sufficient guarantees with regard to the requirements of the General Data Protection Regulation (RGPD: n° 2016-679).

What security measures?

To ensure the security and confidentiality of Personal Data and Personal Health Data, SKEZI uses networks protected by standard devices such as firewalls, pseudonymization, encryption and passwords.

SKEZI undertakes to take all technical and organizational measures to ensure the protection, security and confidentiality of the Personal Data of the persons concerned, in particular against any loss, alteration, distribution or illegal use.

SKEZI ensures that such measures are in place for all operations carried out in the context of its processing, and in particular during the collection of Personal Data, their storage and their hosting.

In this respect, SKEZI also ensures that the third parties it may call upon (technical service providers, suppliers...) respect this requirement of protection of Personal Data by implementing appropriate measures, in accordance with the GDPR. The technical and organizational measures implemented may include the use of secure registration forms, encryption and/or restricted access to Personal Data. Within the limits of their respective attributions and for the purposes recalled above, the main persons likely to have access to the data of SKEZI Users are mainly the agents of our customer service.

SKEZI invites the concerned persons to be very careful when communicating, by their care to third parties, their Personal Data but also their personal identifiers and passwords allowing their access to the site.

If you receive a message that appears to be a phishing attempt, please do not respond and do not open any attachments, images or links contained in the message.

What are the users' rights?

In accordance with the European regulations in force, the Users of the SKEZI website have the following rights:
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- right of access (article 15 GDPR) and rectification (article 16 GDPR), update, completeness of Users' data right of blocking or deletion of Users' personal data (article 17 RGPD), when they are inaccurate, incomplete, equivocal, outdated, or whose collection, use, communication or storage is forbidden
- right to withdraw consent at any time (Article 13-2c GDPR)
- Right to limit the processing of Users' data (Article 18 GDPR)
- right to object to the processing of Users' data (Article 21 GDPR)
- the right to portability of data provided by Users, where such data are subject to automated processing based on their consent or on a contract (Article 20 GDPR)
- the right to define the fate of the Users' data after their death and to choose to whom SKEZI shall communicate (or not) their data to a third party that they have previously designated

As soon as SKEZI becomes aware of the death of a User and in the absence of instructions from the User, SKEZI undertakes to destroy the User's data, unless it is necessary to keep the data for evidentiary purposes or to comply with a legal obligation.

If the User wishes to know how SKEZI uses his Personal Data, wants to ask to rectify them or to oppose their processing, the User can contact SKEZI in writing at the following address
SKEZI – DPO, 1, rue Jean Jaurès, 74000 Annecy/ Or by mail DPO

A request by post must be presented personally and in writing, signed and accompanied by a photocopy of an identity document bearing the signature of its holder. This information will only be communicated for the purpose of identifying the person concerned and will not be kept for a period exceeding that required to process the reply. The request will specify the email or postal address to which the eventual reply should be sent.
SKEZI will have a period of one month to answer following receipt of the request. This period may be extended by two months in case of complexity or high number of requests. If this happens, SKEZI will inform the user in accordance with article 12.3 of the GDPR.

Each data subject is informed that the exercise of his/her rights does not affect the validity of the processing operations previously carried out, nor the right of SKEZI to archive some of the Personal Data in question, in accordance with the principles stated above.

In the event of a dispute, the data subject has the right to make a request directly to the competent control authority (CNIL).

Changes to the privacy policy

This Privacy Policy may be changed by SKEZI at any time.
In case of modification of the Privacy Policy, the new version in force will be applicable to the user from the moment he/she connects to the website. In case of a dispute between the user and SKEZI regarding the processing of Personal Data in relation to the use of the SKEZI website, the Privacy Policy to be taken into account will be the one in force at the time of the facts that gave rise to the dispute.

Incident notification

Despite our best efforts, no method of transmission over the Internet and no method of electronic storage is completely secure. Therefore, we cannot guarantee absolute security. If we become aware of a security breach, we will notify affected users so that they can take appropriate action. Our incident notification procedures take into account our legal obligations, whether at national or European level. We are committed to fully informing our customers of all matters relating to the security of their account and to providing them with all the necessary information to help them meet their own regulatory reporting obligations.

No personal information of the user of the SKEZI website is published without the user's knowledge, exchanged, transferred or sold on any support to third parties. Only the hypothesis of the purchase of SKEZI and its rights would allow the transmission of the said information to the eventual buyer who would be in turn held with the same obligation of conservation and modification of the data towards the user of the SKEZI website.

Hypertext links "cookies"

The SKEZI website contains a number of hyperlinks to other websites, set up with the authorization of SKEZI.

However, SKEZI does not have the possibility to check the content of the sites thus visited, and will not assume any responsibility for this fact.

Unless you decide to deactivate the cookies, you accept that the site can use them. You can deactivate these cookies at any time, free of charge, using the deactivation options offered to you and recalled below, knowing that this may reduce or prevent access to all or part of the Services offered by the site.

"cookies"

A "cookie" is a small information file sent to the User's browser and stored within the User's terminal (e.g. computer, smartphone), (hereinafter "Cookies"). This file includes information such as the User's domain name, the User's Internet service provider, the User's operating system, and the date and time of access. Cookies do not damage the User's terminal in any way.
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SKEZI may process the User's information concerning his visit to the Site, such as the pages consulted, the searches made. This information allows SKEZI to improve the content of the Site and the User's navigation. 
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Since Cookies facilitate navigation and/or the provision of services offered by the Site, the User may configure his browser to allow him to decide whether or not he wishes to accept them so that Cookies are recorded in the terminal or, on the contrary, that they are rejected, either systematically or according to their sender. The User can also configure his browser software so that he is offered to accept or reject Cookies from time to time, before a Cookie is likely to be saved in his terminal. SKEZI informs the User that, in this case, it is possible that not all the functionalities of his navigation software are available.

If the User refuses the storage of Cookies in his terminal or browser, or if the User deletes those stored there, the User is informed that his navigation and experience on the Site may be limited. This could also be the case when SKEZI or one of its service providers cannot recognize, for technical compatibility purposes, the type of browser used by the terminal, the language and display settings or the country from which the terminal seems to be connected to the Internet.

If necessary, SKEZI declines any responsibility for the consequences linked to the degraded functioning of the Site and of the services possibly proposed by SKEZI, resulting (i) from the refusal of Cookies by the User (ii) from the impossibility for SKEZI to record or to consult the Cookies necessary for their functioning because of the User's choice. For the management of the Cookies and the User's choices, the configuration of each browser is different. It is described in the help menu of the browser, which will allow to know how the User can modify his wishes concerning Cookies.

At any time, the User can choose to express and modify his wishes regarding Cookies. SKEZI may also use the services of external service providers to help it collect and process the information described in this section.

Finally, by clicking on the icons dedicated to the social networks Twitter, Facebook, Linkedin and Google Plus appearing on the SKEZI Website or in its mobile application and if the User has accepted the deposit of cookies by continuing his navigation on the SKEZI Website or mobile application, Twitter, Facebook, Linkedin and Google Plus may also deposit cookies on your terminals (computer, tablet, cell phone).These types of cookies are deposited on your terminals only if you consent to them. These types of cookies are only deposited on your terminals if you consent to them. At any time, the User can nevertheless withdraw his consent to SKEZI depositing this type of cookies.