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Privacy Policy

Last updated: April 6, 2021

S GOBERT company places great importance on privacy and data protection. In the context of organizing contests, S GOBERT company collects personal data concerning you in a spirit of loyalty and transparency in accordance with the Data Protection Act of January 6, 1978 as amended in 2004, the Law for Confidence in the Digital Economy ("LCEN") of June 21, 2004 and the General Data Protection Regulation ("GDPR") 2016/679 of April 27, 2016.

This Privacy Policy is intended to describe the types of personal information we collect, how it is used, and how the protection of this data and your rights are ensured.

By participating in contests, you declare that you have understood and accepted the practices described in this Privacy Policy.

A — Types of Data Collected and Processing Purposes

A.0 — Preamble — Data Storage

Please note that our data storage services/units are located in the EU:

Amazon Web Services, Inc.
P.O. Box 81226
Seattle, WA 98108-1226
https://aws.amazon.com

Data Center Location: IRELAND
EU-US Data Protection Shield:
https://www.privacyshield.gov

A.1 — Personal Data

The concept of personal data refers to any information relating to an identified or identifiable natural person.

As part of your registration and participation in the contest, you voluntarily provide us with data concerning you:

  • Your name, first name, age, title, date of birth, email address, postal address and telephone number (landline and/or mobile); and any other data that could appear on the registration form, provided that this data is in no way categorized as sensitive.

As part of your registration and participation in the contest, you will never be asked to provide sensitive personal data. By sensitive personal data we mean, in accordance with the GDPR:

  • your racial or ethnic origin; your political opinions, religious or philosophical beliefs; your trade union membership; processing of genetic data; biometric data for the purpose of uniquely identifying a natural person; data concerning your health; data concerning your sex life; your sexual orientation.

As part of your registration and participation in the contest, we may ask qualifying questions about your preferences, interests, and user behavior:

  • data relating to your family situation and consumption habits such as marital status, number of household members, number and age of child(ren) in the household, socio-professional group, owner/tenant status, …

Please note that all fields in the contest participation form are mandatory in order to participate in the contest.

As part of your navigation on our website, we may collect certain information relating to your browsing:

  • navigation data such as IP address and communication information made available through the use of your computer are collected automatically. This data is used only for purposes related to dispute resolution. Furthermore, statistical data may be collected during your visit and used.

In the case of an online survey, all your responses are kept strictly confidential and no link is made between your survey responses and your personal data.

A.2 — Identity and Contact Details of the Data Controller

The personal data collected is subject to computer processing for which the controller is the company S GOBERT, EURL with capital of 15,000 euros, whose registered office is located at 16 rue Paul Bert 92400 Courbevoie — FRANCE, registered with the Paris Trade and Companies Register under number 794602201.

In accordance with the provisions of Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms, our company has been declared to the CNIL (National Commission for Data Protection and Freedoms), registration number: 1560281.

In addition to our postal address, you also have the option to contact us using this email address: pkrstan@gmail.com

If you agree to transmit your personal data to receive offers from partners identified on the page at the time of collection, the data controllers are each of the partners indicated at the time of the action.

In any case, S GOBERT cannot be held responsible for processing carried out by these partners. For this reason, we invite you to review their respective privacy policies.

A.3 — Processing Purposes and Legal Basis

A.3.1) The personal data you voluntarily provide to us is collected and may be processed for the following purposes:

  • Management of the data subject's participation in the contest: the processing of this data is necessary to take into account your participation, to conduct the contest, to determine the winner and to process the prizes, in particular to inform the winner and to send the prize, to manage requests to exercise the rights of the data subject and in order to comply with our legal and regulatory obligations.
  • Conducting advertising campaigns by third parties, studies and surveys by S GOBERT company: for this purpose, the data of the data subjects must be subject to normalization, deduplication, filtering and verification operations. Third-party advertising will be sent by S GOBERT company. You can stop our solicitations at any time by unsubscribing from our communications or by contacting us. This processing is optional and only applies if you expressly agree to receive commercial offers from S GOBERT. In accordance with applicable regulations, your participation in the contest is not conditional on accepting commercial offers.
  • Conducting advertising campaigns by third parties, studies and surveys by our monetization partners on behalf of S GOBERT: for this purpose, the data of the data subjects must be subject to normalization, deduplication, filtering and verification operations. Third-party advertising will be sent by our monetization partners on behalf of S GOBERT. These monetization partners cannot in any way freely use your data (they do not own your data). A contractual relationship requires them to use your data only on behalf of our company and to destroy it if we request it. You can stop their solicitations at any time by unsubscribing from their communications or by contacting us. This processing is optional and only applies if you expressly agree to receive commercial offers from S GOBERT. In accordance with applicable regulations, your participation in the contest is not conditional on accepting commercial offers.
  • Transmission of data to contest sponsors for the purpose of conducting commercial solicitation operations in various business sectors: for this purpose, the data of the data subjects will necessarily be subject to normalization, deduplication, filtering, verification operations and may be used for targeting and analysis functionalities. Advertising will be sent by third parties. This processing is optional and only applies if you expressly agree to receive offers from sponsors and that your data be transmitted to them. In accordance with applicable regulations, your participation in the contest is not conditional on accepting commercial offers.

Advertising campaigns sent by both S GOBERT company and third parties may be conducted through the following channels: email, postal mail, telephone calls, SMS and/or MMS messages, Web Push or any similar means of communication.

  • Management of requests for access, rectification, erasure, objection and data portability rights.
  • Justification in case of dispute and compliance with our legal and regulatory obligations.

A.3.2) The justification for processing your data concerning the purposes listed in article A.3.1 is based on:

  • For the management of the data subject's participation in the contest: the performance of the contract for the distribution of prizes and gifts following the draws we organize.
  • For conducting advertising campaigns by third parties and studies and surveys by S GOBERT company: the consent of the data subject.
  • For the transmission of data to third parties for the purpose of conducting advertising campaigns: the consent of the data subject.

By this Privacy Policy, you are informed of the terms and conditions for processing your personal data. You can express your prior and express consent to the collection and processing of your personal data by S GOBERT company on the Site, in compliance with the provisions of the GDPR.

B — Data Retention Period

All personal data collected is retained for a limited period depending on the purpose of processing and only for the period provided by applicable legislation.

Personal data collected to participate in the contest will be retained for the duration of the contest and after the expiration of the contest, for the time necessary to designate the winner, to manage the prizes and any claims, for a total maximum period of three years. At the end of this period, the data is destroyed in accordance with the measures prescribed by applicable legislation.

The data of the data subjects will be retained for the purposes of our commercial actions and prospecting for which the data was collected until your request for cancellation, limitation or erasure, and within three years from their collection by the data controller or from the last contact from the prospect. At the end of this period, the data is destroyed in accordance with the measures prescribed by applicable legislation.

C — Recipients of Personal Data

S GOBERT company is committed to protecting and securing the personal data you have agreed to provide to us in order to prevent it from being disclosed to unauthorized third parties. However, if we are legally required to do so or if a court decision requires it, we will communicate your data to the extent necessary to comply with this law or court decision.

The personal data collected may be communicated to authorized personnel of S GOBERT company, its business partners, if you have given your express consent, or its ancillary service providers, in the context of performing all or part of the services.

The data collected may, where applicable, be transmitted to subcontracting companies to which the data controller may resort in the context of performing the services. The data controller ensures compliance with data protection requirements for all its subcontracting companies.

D — Data Security and Confidentiality

We implement organizational and technical security measures designed to guarantee the confidentiality and integrity of your personal data. To this end, administrative, organizational, technical and physical precautions are intended to protect your personal data from loss, theft, misuse, unauthorized access, unauthorized transmission, any modification or undue destruction.

In all cases, the data controller will take security measures appropriate to the nature of the data collected.

The data collected is stored confidentially and protected at a very high level of security. The servers where this data is stored comply with current security standards. They are protected against digital and physical attacks.

However, despite all our efforts, we cannot guarantee the infallibility of this protection due to unavoidable risks that may occur during the transmission of personal data.

E — Rights of Data Subjects

Under applicable legislation, you have the following rights concerning your personal data, where applicable:

  • Right of access, rectification, erasure of your personal data;
  • Right to portability of data concerning you;
  • Right to object to processing justified by a legitimate interest, or to prospecting;
  • Right to restrict the processing of data concerning you;
  • Right to unsubscribe from our company and/or our partners;
  • Right to communicate your directives regarding the fate of personal data concerning you in the event of death.
  • Right not to be subject to a decision based solely on automated processing, including profiling, producing legal effects concerning you or affecting you in a similarly significant manner.

You can exercise your various rights by contacting us: S GOBERT, EURL with capital of 15,000 euros, whose registered office is located at 16 rue Paul Bert 92400 Courbevoie — FRANCE. Please note that we may ask you for proof of identity and we reserve the right to require payment of "reasonable fees" related to administrative costs incurred to provide the information if your request is manifestly unfounded or excessive. We will endeavor to respond to your requests within the required timeframes. In addition to our postal address, you also have the option to contact us using this email address: pkrstan@gmail.com

F — Data Transfer Outside the European Union

Your personal data is stored by us within the European Union.

Some of S GOBERT company's partners are located outside the European Union. In this case, however, it is possible to carry out a secure data transfer in accordance with European data protection regulations.

We ensure that your personal data is effectively protected. Thus, all transfers are made to recipients located:

  • in countries presenting, according to the criteria established by the European Commission, an adequate level of personal data protection;
  • in countries not offering adequate protection but to which the transfer is governed by standard contractual clauses issued by the European Commission or by the adoption of binding corporate rules;
  • in the United States, provided that these recipients meet the conditions set by the Privacy Shield established by the U.S. Department of Commerce.

G — Cookies

In the context of our web pages, we use what are called cookies. These are small text files deposited on your hard drive by the website visited, allowing it to record and store certain information about your computer and about you.

They are essential for the functioning of the internet because they enable proper communication between two computers. The information retrieved is also used to operate applications you use on the website.

By browsing the Site, you consent to cookies as described below being placed on your device subject to any choices you may have expressed in accordance with this Cookie Management Charter.

G.1 — Definition of Cookies

Cookies are small text files, generally composed of letters and numbers, placed on the device you use (computer, tablet, smartphone, etc.) when you visit a website.

They allow the website consulted to control, store and retrieve information about your browsing habits as well as obtain technical communications about the navigability of the site. In this way, cookies allow you to receive personalized services and improve the functionality, user-friendliness and accessibility of the web pages in question.

G.2 — Types and Purposes of Cookies

Depending on their status and purposes, there are different types of cookies listed below. These concern our contest game sites as applicable and/or our email sends.

  • Technical cookies and functionality cookies: these cookies are necessary for the operation of our Site and essential to allow you to navigate and use the features of our Site, such as access to secure areas. These are mainly session cookies or login cookies. The cookies we issue allow us to: count the number of advertisements displayed by us in our advertising spaces, identify these advertisements, their respective number of displays, the number of users who clicked on each advertisement and, where applicable, the subsequent actions taken by these users on the pages to which these advertisements lead, in order to calculate the amounts due to the actors in the advertising distribution chain and to establish statistics; adapt the presentation of our Site to the display preferences of your device when you visit our Site; adapt advertising spaces to the display preferences of your device; keep in memory information relating to a form you filled out on our Site; allow you to access reserved and personal areas of our Site, such as your account; deploy security measures, in particular when you are asked to log in again to content or a service after a certain period of time.
  • Analytical or audience measurement cookies: these are mainly cookies relating to visits to the Site, cookies that analyze the source of the visit, Site performance cookies and statistical or analytical cookies. These cookies allow us to recognize and count the number of visitors and traffic sources in order to measure and improve the performance of our Site. They help us understand why you may encounter difficulties or receive error messages on certain pages, if applicable; determine which pages are most and least visited; analyze visitor navigation on the Site; adapt and improve our Site to make it more useful, more intuitive; and overall, improve the user experience.
  • Social media sharing cookies: these cookies are necessary to manage external social networks (examples: Facebook, Twitter, Pinterest, etc.). Their function is to control the interaction of internet users with social widgets within a web page. Indeed, our Site may contain buttons linked to social networks allowing you to share content from the Site or express your opinion (e.g., "like", "retweet", etc.). If you are logged into the social network while you visit our Site, your browser establishes a connection between the network and the Site. If you click on a social network button placed on the Site, plug-ins (small software) transmit the corresponding information to the social network, which publishes it on your account. If you want to avoid any connection between a social network and the Site, you must log out of the social network before visiting our Site. These cookies are placed directly by social networks. Thus, user choices regarding the placement of these cookies must also be made with the social networks. For this purpose, S GOBERT invites users to consult directly the websites of social networks and their personal data protection policy.
  • Behavioral advertising cookies: these cookies collect information about your browsing habits in order to identify your preferences and specific interests. They serve to identify the user profile in order to display targeted advertising in real time based on your interests, via our email sending programs and those of our partners where applicable and on other sites you visit and on which our partner has placed the same cookies. These cookies thus allow you to personalize advertising content according to your preferences. They may come from our partners as well as third parties and may be placed either by browsing the Site or by viewing our emails. The objective is to present you with the most relevant possible advertisements, close to your interests. For this purpose, cookie technology makes it possible to determine which advertisement to display to a terminal, based on recent browsing on one or more websites.
  • Partner marketing cookies : marketing cookies are held by partners and used to provide you with targeted advertisements and offers throughout your online experience (web, email, applications, etc.). These cookies may be deposited either by browsing the Site or by consulting our emails. Cookies may be included in advertising spaces on our Site. These advertising spaces display advertising content from advertisers on your device. These advertising spaces contribute to financing the content and services we make available to you. The issuance and use of cookies by third parties are subject to the privacy protection policies of these third parties. We inform you of the cookies we are aware of and the means available to you to make choices regarding cookies.

G.3 — Use of cookies on this Site

S GOBERT uses its own cookies, as well as those issued by third parties, for the purposes of monitoring and improving the Site's activity and, where applicable, its email communications. Cookies may be deposited when browsing our Site or following the opening of emails.

  • Google Analytics : S GOBERT uses Google Analytics (third-party cookies) on the Site. This is an analytics service provided by Google, Inc. Through Google Analytics, S GOBERT analyzes your interaction with the Site, tracks your activity on it, and collects data on your browsing habits to allow S GOBERT to measure the Site's performance. Google is a company located in the United States. Consequently, data processed by Google Analytics (including your IP address) may be transferred to the United States and stored on Google's servers located in that country. You can manage and block the processing of your personal data through Google Analytics by configuring the browser used to access the Site. For more information about Google Analytics, click here: https://support.google.com/analytics/answer/3455585?hl=en. Furthermore, you can disable Google Analytics. To do so, you must install an opt-out option. For more information about this opt-out option, click here: https://tools.google.com/dlpage/gaoptout.
  • Case of third-party content distributed in our advertising spaces : advertising content (graphics, animations, videos, etc.) distributed in the advertising spaces of our Site may contain cookies issued by third parties: either the advertiser (at the origin of the advertising content in question) or a company third to the advertiser (communication consulting agency, audience measurement company, targeted advertising service provider, etc.) that has associated a cookie with an advertiser's advertising content. Where applicable, cookies issued by these third parties may allow them, during the validity period of the cookies: to count the number of displays of advertising content distributed via the advertising spaces of our Site, to identify the advertisements displayed, the number of users who clicked on each advertisement, allowing them to calculate the amounts due as a result and to establish statistics; to collect navigation information relating to devices consulting our Site; to recognize your device during subsequent browsing on any other site on which these advertisers or these third parties also issue cookies and, where applicable, to adapt these websites or the advertisements they distribute to your device's browsing, which they may thus have knowledge of.
  • Case of external advertising networks operating our advertising spaces : the advertising spaces of our Site may be operated by one or more external advertising network(s) and contain cookies issued by this/these network(s). Where applicable, cookies issued by these external advertising networks allow them, during the validity period of the cookies: to count the total number of advertisements displayed by them on our advertising spaces, to identify these advertisements, their respective number of displays, the number of users who clicked on each advertisement and, where applicable, subsequent actions performed by these users on the pages to which these advertisements lead, in order to calculate the amounts due to the players in the advertising distribution chain and to establish statistics; to adapt the advertising spaces they operate to your device's display preferences; to adapt the advertising content displayed on your device via our advertising spaces according to your device's browsing on our Site; to adapt the advertising content displayed on your device via our advertising spaces according to the previous or subsequent browsing of your device on third-party websites within which the network in question also issues cookies; to adapt the advertising content displayed on your device via our advertising spaces based on location data transmitted by your device with your prior consent; to adapt the advertising content displayed on your device in our advertising spaces based on personal data you may have provided to this advertising network.

G.4 — Cookie settings on this Site

You can freely choose at any time to express and modify your wishes regarding cookies, by the means described in this Privacy Policy.

The recording of a cookie on a device remains subject to the expression of the device user's will, which they can express and modify at any time and free of charge through the choices offered by their browsing software.

If you refuse the recording of cookies on your device or if you delete those recorded on it, you may no longer be able to benefit from a number of features that may nevertheless be necessary to navigate certain sections of our Site. This would be the case if you attempted to access our content or services that require you to identify yourself. This would also be the case when we and/or our service providers and/or partners could not recognize, for technical compatibility purposes, the type of browser used by your device, its language and display settings, or the country from which your device appears to be connected to the internet.

Where applicable, we disclaim any responsibility for the consequences related to the degraded functioning of our services resulting from the impossibility for us to record or consult the cookies necessary for their functioning and that you would have refused or deleted. In the event that you choose not to accept the receipt of cookies on your device's hard drive, the Site's functioning may not be optimal from your device, particularly in the event of a file upload procedure.

To manage cookie activity, block them, or delete them, simply manage the settings of the browser used to access the Site. Otherwise, browsing the Site implies your acceptance of the use of cookies, in accordance with what is indicated in this Cookie Management Charter. Each browser's configuration is different. As an indication, you can find instructions for different browsers at the following addresses:

PC Browsers:

Browsers on mobile devices:

You can also visit the Youronlinechoices website, offered by digital advertising professionals, grouped within the European association EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France to modify your cookies' activity, block them, or delete them. This site offers you a cookie management platform shared by hundreds of professionals, allowing you to accept or refuse their cookies in their entirety or on a case-by-case basis. Youronlinechoices is accessible via the link: http://www.youronlinechoices.com/fr/controler-ses-cookies/

If your device is used by multiple people and if your device has multiple browsing software, we cannot ensure with certainty that the services and advertisements intended for your device correspond to your personal use of this device and not that of another user of the same device. Where applicable, sharing the use of your device with other people and configuring your browser's settings regarding cookies are matters of your free choice and responsibility.

G.5 — Cookie retention period

In any case, cookies stored on your device or any other element used to identify you for statistics or audience purposes will have a reasonable lifespan for the purpose of the intended processing, limited to a maximum of thirteen (13) months, this period not being automatically extended during your subsequent visits to the Site. Beyond this, raw traffic data associated with an identifier are either deleted or anonymized.

G.6 — Additional information about cookies

For more information about cookies and how they work, visit the following page: http://www.allaboutcookies.org/. You can also consult the page dedicated to cookies on the CNIL website (National Commission for Computing and Freedoms) via the following link: http://www.cnil.fr/vos-droits/vos-traces/les-cookies/

H — Links to other websites and services

It is specified that certain links in the game allow access to third-party sites and give you access to third-party services (such as social networks).

We have no control over how third-party sites and services handle your personal information. We do not verify third-party sites and services, and we are not responsible for these third-party sites and services or their privacy practices. We invite you to refer to the privacy policies or privacy statements of third-party sites or services that you access from our sites or services.

Our privacy policy only concerns information collected on our site. As such, S GOBERT cannot be held responsible for the use of your data on these other sites.

I — Bloctel

When participating in the game, if you authorize S GOBERT or its partners to call you by telephone, this means that you accept receiving offers from them or their partners.

We inform you of the existence of the "Bloctel" telephone marketing opt-out list, on which you can register here: https://conso.bloctel.fr/

J — Modification of the privacy policy

This Privacy Policy may be updated at any time, in particular in application of changes made to applicable laws and regulations. We therefore invite you to regularly review updates.