Data privacy policy

Last update: April 06, 2021

The company S GOBERT attaches great importance to confidentiality and data protection. As part of the organization of contests, the company S GOBERT collects personal data concerning you in a spirit of loyalty and transparency in accordance with the Data Protection Act of 6 January 1978 amended in 2004, the Law for Confidence in the Digital Economy (“LCEN”) of 21 June 2004 and the General Data Protection Regulation (“RGPD”) 2016/679 of 27 April 2016.

La présente Politique de confidentialité a pour objet de décrire les types d’informations personnelles que nous recueillons, l’utilisation qui en est faite et comment la protection de ces données ainsi que vos droits sont assurés.

By participating in the contests, you declare that you understand and agree to the practices described in this Privacy Policy.

A - Type of data collected and processing purposes

A.0 - Preamble - Data Storage

Please note that our data storage services/units are located in the E.U.:

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

Datacenter location: IRLANDE
EU-US Privacy Shield:
https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4

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 game, you voluntarily provide us with data about yourself:

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

Dans le cadre de votre inscription et de votre participation au jeu, il ne vous sera jamais demandé de communiquer des données à caractère sensibles. Par données à caractère sensibles nous entendons, en adéquation avec la RGPD :

• your racial or ethnic origin; your political opinions, your religious or philosophical beliefs; your trade union membership; the 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 game, we may ask qualifying questions about your preferences, your interests, your user behavior:

• data relating to your family situation and your consumption habits such as married life, number of persons in the household, number and age of the child (ren) in the household, socio-professional group, owner/tenant situation,...

Please note that all fields in the game entry form are mandatory in order to participate in the game.

As part of browsing our website, we are likely to collect certain information relating to your browsing:

• browsing data such as the IP address and communication details that are made available as a result of the use of your computer are collected automatically. This data is only used for purposes relating to the resolution of disputes. In addition, 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 whose manager is the company S GOBERT, EURL with a capital of 15,000 euros, whose head office is located 16 rue Paul Bert 92400 Courbevoie - FRANCE, registered with the Paris Trade and Companies Register, registered with the Paris Trade and Companies Register under number 794602201.

In accordance with the provisions of Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms, our company has been the subject of a declaration to the CNIL (Commission Nationale Informatique et Liberté), registration number: 1560281.

In addition to our postal address, you can also contact us using this contact email: hither

If you agree to transmit your personal data to receive offers from the 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 event, S GOBERT cannot be responsible for the treatment carried out by these partners. To do this, we invite you to read their respective privacy policies.

A.3 - Processing purposes and legal basis

A.3.1) Les données à caractère personnel que vous nous communiquez volontairement sont récoltées et susceptibles d’être traitées pour les finalités suivantes :

• Management of the interested person's participation in the competition: the processing of this data is necessary to take into account your participation, to carry out the competition, to determine the winner and to process the winnings, in particular to inform the winner and to send the prize, to manage requests to exercise the rights of the person concerned and for the purpose of complying with our legal and regulatory obligations.

• Carrying out advertising activities by third companies, studies and surveys on the part of the company S GOBERT: to this end, the data of the persons concerned must be subjected to standardization, deduplication, filtering and verification operations. Third-party advertising will be sent by the company S GOBERT. You can stop our requests at any time by unsubscribing from our communications or by contacting us. This treatment is optional and only applies if you expressly agree to receive commercial offers from S GOBERT. In accordance with current regulations, your participation in the game is not conditional on your acceptance of receiving commercial offers.

• Carrying out advertising activities by third companies, studies and surveys on behalf of our monetization partners on behalf of S GOBERT : To this end, the data of the persons concerned must be subject to standardization, deduplication, filtering and verification operations. Third-party advertising will be sent by our monetization partners on behalf of S GOBERT. Under no circumstances can these monetization partners 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 solicitation at any time by unsubscribing from their communications or by contacting us. This treatment is optional and only applies if you expressly agree to receive commercial offers from S GOBERT. In accordance with current regulations, your participation in the game is not conditional on your acceptance of receiving commercial offers.

• Transmission of data to game sponsors for the purpose of carrying out commercial solicitation operations in various business sectors : For this purpose, the data of the persons concerned will necessarily be subject to standardization, deduplication, filtering, verification and may be used for targeting and analysis functionalities. The advertising will be sent by third party companies. This processing is optional and only applies if you expressly agree to receive offers from sponsors and your data to be transmitted to them. In accordance with current regulations, your participation in the game is not conditional on your acceptance of receiving commercial offers.

• Management of requests for the right of access, rectification, erasure, opposition and portability.

• Justification in the event of a dispute and compliance with our legal and regulatory obligations.

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

• To manage the participation of the interested person in the competition: the execution of the contract for the distribution of prizes and gifts following the draws that we organize.

• For the implementation of advertising activities by third companies and studies and surveys by the company S GOBERT: the consent of the person concerned.

• For the transmission of data to third companies for the purpose of carrying out advertising activities: the consent of the person concerned.

Through 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 the company S GOBERT on the Site, in accordance with the provisions of the RGPD.

B - Data Retention Period

The personal data collected to participate in the game will be kept throughout the duration of the game and after the expiration of the game, for the duration necessary to designate the winner, manage prizes and possible claims, i.e. a maximum total duration of three years. At the end of this period, the data is destroyed in accordance with the measures prescribed by the legislation in force.

The data of the persons concerned will be kept for the purposes of our commercial activities and prospecting for which the data was collected until your request for cancellation, limitation or erasure, and within the limit of three years from their collection by the data controller or the last contact from the prospective customer. At the end of this period, the data is destroyed in accordance with the measures prescribed by the legislation in force.

C - Recipients of personal data

The company S GOBERT takes care to protect and secure the personal data that you have agreed to communicate to us in order to prevent them from being disclosed to unauthorized third parties. However, if we are legally obliged to do so or if a court order requires us to do so, we will communicate your data to the extent necessary to comply with this law or court order.

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

The data collected may, where appropriate, be transmitted to subcontracting companies that the data controller may call upon in the context of the performance of 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 to ensure the confidentiality and integrity of your personal data. As such, administrative, organizational, technical and physical precautions aim to protect your personal data from loss, theft, abuse of use, unauthorized access, unauthorized transmission, modification or undue destruction.

In all cases, the data controller will take security measures adapted 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 the security standards currently in force. They are protected against digital attacks and physical attacks.

However, despite our best efforts, we cannot guarantee the infallibility of this protection due to inevitable risks that may arise during the transmission of personal data.

E - Rights of the persons concerned

Under applicable law, you have the following rights with respect to your personal data, where applicable:

• Right to access, rectify and delete your personal data;

• Right to the portability of data concerning you;

• Right to object to treatment justified by a legitimate interest, or to prospecting;

• Right to limit the processing of data concerning you;

• Right to unsubscribe from our company and/or our partners;

• Right to communicate your instructions concerning the fate of personal data concerning you in the event of death.

• Right not to be the subject of a decision based exclusively on automated processing, including profiling, that produces legal effects concerning you or significantly affects you in a similar way.

You can exercise your various rights by contacting us: S GOBERT, EURL with a capital of 15,000 euros, whose head office is located at 16 rue Paul Bert 92400 Courbevoie - FRANCE. Please note that we may ask you for proof of identity and that we reserve the right to require payment of a “reasonable fee” related to the administrative costs incurred in providing the information if your request is clearly unfounded or excessive. We will do our best to respond to your requests within the required timeframe. In addition to our postal address, you can also reach us using this contact email: ici

F - Data transfer outside the European Union

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

Some of S GOBERT's partners are located outside the European Union. In this case, however, it is possible to carry out a secure transfer of data 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, in accordance with criteria established by the European Commission, an adequate level of protection of personal data;

• in countries that do not offer adequate protection but to which the transfer is governed by the standard contractual clauses laid down by the European Commission or by the adoption of binding corporate rules;

• in the United States, provided that these recipients meet the conditions set out by the Privacy Shield established by the Department of Commerce in the United States.

G - Cookies

As part of our Internet pages, we use what are known as cookies. These are small text files placed on your hard drive by the website visited, allowing it to record and store certain information about your computer but also about you.

They are essential for the functioning of the Internet because they allow good communication between two computers. The information collected is also used to operate the applications that you use on the website.

By browsing the Site, you agree that cookies as described below may be placed on your terminal subject to the choices that you would 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 site thus consulted to monitor, store and retrieve information on your browsing habits as well as to obtain technical communications on the navigability of the site. In this way, cookies make it possible to provide you with personalized services such as improving the functionality, usability and accessibility of the web pages concerned.

G.2 - Type and purpose of cookies

Depending on their status and purposes, there are different types of cookies listed below. These concern our competition sites, depending on the case, and/or our sending of emails.

• Technical cookies and functionality cookies: These cookies are necessary for the functioning of our Site and essential to allow you to browse 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 on our advertising spaces, to identify these ads, their respective number of displays, the number of users who clicked on each advertisement and, where appropriate, the subsequent actions carried out by these users on the pages to which these ads lead, in order to calculate the sums due to actors in the advertising distribution chain (communication agency, advertising agency, Site/distribution medium)) and to establish statistics; - to adapt the presentation of our Site to the display preferences of your terminal (operating system used, language, display resolution, etc.) when you visit our Site, depending on the hardware and software for viewing and/or reading that your terminal includes; - to adapt advertising spaces to the display preferences of your terminal (language used, display resolution, operating system used, etc.) when you visit our Site, depending on the hardware and software that you use your terminal includes; - of remember information relating to a form that you have filled out on our Site (registration or access to an account) or to products, services or information that you have chosen; - to allow you to access reserved and personal areas of our Site, such as your account, using identifiers or data that you may have previously given us; - to deploy security measures, in particular when you are asked to connect again to content or a service after a certain period of time.

• Analytical or audience measurement cookies : These are mainly cookies relating to the visit to the Site, cookies that analyze the origin of the visit, Site performance cookies, and statistical or analytical cookies. Ces cookies nous permettent de reconnaitre et de comptabiliser le nombre de visiteurs et les sources de trafic afin de mesurer et d’améliorer la performance de notre Site. Ils nous aident à comprendre pourquoi vous rencontrez des difficultés éventuelles ou recevez des messages d’erreur sur certaines pages, le cas échéant ; à déterminer quelles pages sont les plus visitées et les moins visitées ; à analyser la navigation des visiteurs sur le Site ; à adapter et améliorer notre Site pour qu’il soit plus utile, plus intuitif ; et dans l’ensemble, à améliorer la visite des utilisateurs.

• 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 to express your opinion (e.g. “like”, “retweet”, etc...). If you are connected to the social network while visiting 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, the user's choices regarding the deposit of these cookies must also be made on social networks. To this end, S GOBERT invites users to consult directly the social media websites and their personal data protection policies.

• Behavioral advertising cookies : These cookies collect information about your browsing habits in order to identify your specific preferences and tastes. They are used to identify the user profile in order to display advertising targeted to your interests in real time, via our email sending programs and those of our partners, if applicable, and on other sites that you visit and on which our partner has placed the same cookies. These cookies thus make it possible to personalize advertising content according to your preferences. They may come from our partners as well as third parties and may be deposited either by browsing the Site or by consulting our emails. L'objectif est de vous présenter les publicités les plus pertinentes possibles, proches de vos centres d'intérêt. A cette fin, la technologie des cookies permet de déterminer quelle publicité afficher à un terminal, en fonction de la navigation récente sur un ou plusieurs sites internet.

• Partner marketing cookies: Marketing cookies are owned by partners and used to provide you with targeted advertising and offers throughout your online experience (web, email, applications,...). These cookies can be placed either by browsing the Site or by consulting our emails. Cookies may be included in advertising spaces on our Site. These advertising spaces display, on your terminal, advertising content from advertisers. These advertising spaces contribute to the financing of the content and services that we make available to you. The issuance and use of cookies by third parties are subject to the privacy policies of these third parties. We inform you about 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

The company S GOBERT uses its own cookies, like those issued by third parties, with the purpose of continuing and improving the activity of the Site and, where appropriate, its sending of emails. Cookies may be placed when browsing our Site or after opening emails.

• Google Analytics : S GOBERT uses Google Analytics (third party cookies) on the Site. This is an analysis service provided by Google, Inc. Through Google Analytics, S GOBERT analyzes the interaction between you and the Site, tracks your activity on the Site, and collects data on your browsing habits to allow S GOBERT to measure the performance of the Site. Google is a company located in the United States. As a result, data processed by Google Analytics (including your IP address) may be transferred to the United States and stored on Google 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. Pour obtenir plus d’informations sur Google Analytics, cliquez-ici: https://support.google.com/analytics/answer/3455585?hl=en. In addition, you can deactivate Google Analytics. To do this, you need to install an uninstall option. For more information about this uninstallation option, click here: https://tools.google.com/dlpage/gaoptout.

• Case of third-party content disseminated in our advertising spaces : The advertising content (graphics, animations, videos, etc.) displayed in the advertising spaces of our Site may contain Cookies issued by third parties: either the advertiser (at the origin of the advertising content concerned) or a company third party to the advertiser (communication consulting agency, audience measurement company, targeted advertising provider, etc.) that has associated a cookie with an advertiser's advertising content. Where appropriate, the cookies issued by these third parties may allow them, during the period of validity of the cookies:

  • to count the number of displays of advertising content broadcast via the advertising spaces on our Site, to identify the ads 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 browsing information relating to the terminals consulting our Site;
  • to recognize your terminal when you subsequently browse any other site on which these advertisers or these third parties also issue cookies and, where appropriate, to adapt these websites, or the advertisements they display, to the navigation of your terminal, which they can thus be aware of.

• Case of external advertising agencies exploiting our advertising spaces : The advertising spaces on our Site may be operated by one or more external advertising agencies and contain cookies issued by this/these advertising agencies. Where appropriate, the cookies issued by these external advertising agencies allow them, during the period of validity of the cookies:

  • de count the total number of advertisements displayed by them on our advertising spaces, identify these ads, their respective number of displays, the number of users who clicked on each advertisement and, if applicable, the subsequent actions carried out by these users on the pages to which these advertisements lead, in order to calculate the sums due to the actors in the advertising distribution chain (communication agency, advertising agency, Website/distribution medium) and to establish statistics;
  • to adapt the advertising spaces they operate to the display preferences of your terminal (language used, display resolution, operating system used, etc.) depending on the hardware and viewing and reading software that your terminal includes;
  • to adapt the advertising content displayed on your terminal via our advertising spaces according to the navigation of your terminal on our Site;
  • to adapt the advertising content displayed on your terminal via our advertising spaces according to the previous or subsequent browsing of your terminal on third-party websites where the agency concerned also issues cookies, provided that these cookies have been saved on your terminal in accordance with the choices you have made with respect to this network;
  • to adapt the advertising content displayed on your terminal via our advertising spaces according to the location data (longitude and latitude) transmitted by your terminal with your prior agreement;
  • to adapt the advertising content displayed on your terminal in our advertising spaces according to the personal data that you could have provided to this advertising network.

G.4 - Setting cookies on this Site

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

The registration of a cookie on a terminal remains subject to the expression of the will of the user of the terminal, which the user can express and modify at any time and free of charge through the choices offered to him by his browser software.

If you refuse to save cookies on your device or if you delete those saved there, you may no longer be able to benefit from a certain number of functionalities that may nevertheless be necessary to navigate certain sections of our Site. This would be the case if you tried 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 terminal, its language and display settings or the country from which your terminal seems to be connected to the Internet.

Where applicable, we decline all responsibility for the consequences related to the degraded functioning of our services resulting from the impossibility for us to save 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 reception of cookies on your terminal's hard drive, the functioning of the Site may not be optimal from your terminal, especially 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 by this Cookie Management Charter. The configuration of each browser is different. Below we show you how to configure the main browsers. For information purposes, and without us being able to guarantee their proper functioning, you can find the instructions on the various browsers at the following addresses (temporary or permanent):

PC browsers:

• Internet Explorer™
• Mozilla Firefox™
• Google Chrome™
• Apple Safari™
• Opera™
• If you don't use any of the browsers on this list, go directly to your browser's help menu to find out how to set it up.

Browsers on mobile devices:

• IOS
• Android
• Windows Phone
• If you don't use any of the browsers on this list, go directly to your browser's help menu to find out how to set it up.

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 the activity of your cookies, 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 full or on a case-by-case basis. Youronlinechoices is accessible under the link: http://www.youronlinechoices.com/fr/controler-sescookies/

If your terminal is used by several people and if your terminal has several browser software, we cannot ensure with certainty that the services and advertising intended for your terminal correspond to your personal use of this terminal and not to that of another user of this same terminal. Where appropriate, sharing the use of your terminal with others and configuring your browser settings with regard to cookies is your free choice and responsibility.

G.5 - Retention period of cookies

In any event, the cookies stored in your terminal or any other element used to identify you for statistical or audience purposes will have a reasonable lifespan for the purpose of the intended processing within the limit of a maximum of thirteen (13) months, this duration being not automatically extended when you visit the Site again. Beyond that, the raw attendance data associated with an identifier is either deleted or anonymized.

G.6 - Additional information on cookies

H - Links to other websites and services

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

We do not have control over how third party sites and services handle your personal information. We do not review third-party sites and services, and we are not responsible for these third-party sites and services or their privacy practices. We encourage 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 applies to information collected on our site. As such, the company S GOBERT cannot be responsible for the use of your data on these other sites.

I - Bloctel

When participating in the game, if you allow S GOBERT or its partners to call you by phone, this means that you agree to receive offers from it or its partners.

We inform you of the existence of the “Bloctel” cold calling 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, including in accordance with changes in current laws and regulations. We therefore invite you to regularly review the updates.