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PRIVACY AND COOKIES POLICY - Verne Legal

PRIVACY AND COOKIES POLICY

1. GENERAL INFORMATION

According to the requirements of the General Data Protection Regulation (GDPR) that entered into force on May 25, 2018, Verne Legal SARL, with its registered office at 418, rue du Mas de Verchant – BP 12 – 34935 Montpellier Cedex 9, in France (hereinafter “VL”) would like to provide some details concerning the personal data processing by VL.

Our goal is to provide a complete, clear and transparent information to each Website visitor (hereinafter the “User”) on how he/she can assure the effective protection of his/her private sphere of life. Therefore, VL shares all information regarding this protection in this Privacy and Cookies Policy. In all matters concerning the processing of personal data and cookies, please contact us at info@20200224verne.fastpages.pl.

2. COLLECTED INFORMATION

When using the Website, User data is automatically collected. These data include IP address, domain name, browser type and version, operating system and language. These data can be collected by cookies, Google Analytics and the Web Beacon system, and can be saved in server logs.

The personal data provided by the Users on the Website is voluntary. They are defined as any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

3. DATA CONTROLLER

Verne Legal law firm acts as the data controller.
In order to contact the controller, please send an e-mail to info@20200224verne.fastpages.pl or contact us in writing, sending your request/question to the following address:
Ewa Kaluzinska
Verne Legal
418, rue du Mas de Verchant – BP 12 – 34935
Montpellier Cedex 9, France
Email: info@20200224verne.fastpages.pl
Tel: +48 22 427 87 10

4. PERSONAL DATA
4.1. Data processing carried out by VL

As a result of browsing the Website, the Administrator collects and processes personal data in accordance with the relevant provisions, including in particular the GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95 /46/EC), and the rules for their processing contained therein.

The Controller ensures the transparency of data processing, in particular, by always informing the User about the processing of data at the time of data collection, its purpose and the legal grounds. The Controller ensures that the data is collected only to the extent necessary for the indicated purpose and only for as long as the processing is necessary.
When processing of Users’ data, the Administrator ensures their security and confidentiality. It guarantees the access to data to the Users concerned. If, despite the security measures, there has been a violation of personal data protection (e.g. “leakage” of data or their loss), the Controller shall inform the Users about such event in a manner conform with the provisions.

As part of its activities, VL collects and processes personal data based on:
Art. 6. 1 f) GDPR – processing is necessary for the purposes of the legitimate interests pursued by the controller (namely VL): to provide services to their clients, for marketing of VL services, including to inform about events organized by VL or in which VL participates and about other VL activities, as well as for analytical, statistical purposes, as well as to ensure 20200224verne.fastpages.pl website cybersecurity;
Art. 6. 1 c) and art. 6.1 a) GDPR – to recruit people interested in working or cooperating with VL;
Art. 6.1 c) GDPR– processing is necessary for compliance with a legal obligation to which the controller is subject;

Therefore, the User’s data are processed mainly, but not exclusively, to present LV services, handle the queries from the contact form, send an e-book and a company newsletter, as well as in case of recruitment procedures.

4.2. Data recipients

The recipients of User’s personal data may be appropriately authorized employees and associates of VL, as well as, depending on the situation, external processing entities, including in particular the IT suppliers (hosting). They provide us with a hosting service and diverse systems of online marketing, both for sending emails and analysing website traffic. The list of suppliers is given in art. 2 of this Privacy and Cookies Policy.
We use suppliers who do not act solely on our demand and will determine the purposes and ways of using the User’s personal data themselves. They provide advertising campaign services for us. Our suppliers are based mainly in Poland and other countries of the European Economic Area (EEA). We make sure that our suppliers guarantee a high level of personal data protection.
Also, VL may disclose Users’ Data, if requested, to an authorized state authority.

4.3. Storage and processing duration

The duration of data processing and storage depends on the type of service provided and the purpose of the processing. The data processing period may also result from legal provisions. In the case of data processing on the basis of the Administrator’s legitimate interest – e.g. for security reasons – the data are processed for a period of time enabling the implementation of this interest or to enable an effective objection to data processing. If the processing is based on consent, the data is processed until it is withdrawn. When the basis for processing is necessary to conclude and execute the contract obligations, the data is processed until its termination.
The data processing period may be extended if it is necessary to establish and assert claims or queries or elaborate a defence against them. After that time, it will only be processed in the event and to the extent required by law. After the storage duration, backup copies are permanently destroyed or anonymised.

4.4. Rights of persons affected

The User is any natural person visiting the website www.20200224verne.fastpages.pl, whose personal data is collected by the Website and processed by the Controller.
The User is also a person using VL IT applications (chatbox), a person visiting our social media and using social media plugins and tools, as well as an individual conducting e-mail correspondence with VL or applying for a job with VL.
According to recital 39 and art. 13, all natural persons should be made aware of risks, rules, safeguards and rights in relation to the processing of personal data and how to exercise their rights in relation to such processing. Namely, VL enables Users the exercise the following rights:

    • right to be informed about the processing of personal data – in response to the request from the User, the Controller provides information about data processing, including but not limited to the purposes and legal grounds for processing, the scope of data stored, entities to which it is disclosed, and the planned date of deletion of data;
    • right to obtain a copy of User’s data – the Controller provides a copy of the processed data regarding the person submitting the request;
    • right to rectification – the Controller is obliged to remove or correct any inaccuracies or errors of personal data processed and supplement them if they are incomplete;
    • right to deletion – according to art. 17 GDPR, the User can request that the Controller deletes the data, provided the legal requirements have been met. This can be the case if the data are no longer required for the purposes for which they were acquired or otherwise processed.
    • right to restriction of processing – in the event of such request, and provided the legal requirements have been met, the Controller ceases to perform operations on personal data concerned by the restriction and their storage, in accordance with accepted retention rules or until the reasons for limiting data processing cease to exist (e.g. a decision of the supervisory authority allowing further processing of data will be issued);
    • right to data transferability – at User’s request, VL can transfer your data – where technically possible – to another responsible entity. However, this right only applies if the data processing is based on User’s consent or is required to fulfil a contract. It is also possible to request that the data be sent to another entity – however, provided that there are technical possibilities in this regard both on the part of the Controller and that other entity;
    • right to objection to the processing of data for marketing purposes – the User may, at any time, object to the processing of his/her personal data for marketing purposes, without the need to justify such a demand;
    • right to objection to other purposes of data processing – the User may, at any time, object to the processing of personal data based on VL legitimate interest or the User’s consent (e.g. for analytical or statistical purposes or for reasons related to the protection of property); such request must be motivated by the User. In this case, VL will no longer process your data. The latter does not apply if VL is able to prove there are compelling, defensible reasons for the processing that outweigh your interests or we require your data to assert, exercise or defend against legal claims.
    • right to withdraw consent – if the data are processed on the basis of expressed consent, the User has the right to withdraw it at any time. However, it does not affect the lawfulness of the processing carried out before the consent is withdrawn.;
    • right to lodge a complaint – if processing of personal data violates the provisions of the GDPR or other provisions regarding the personal data protection, the User may lodge a complaint with the Commission nationale de l’informatique et des libertés “CNIL” (CNIL, 3 Place de Fontenoy, 75007 Paris).

In order to exercise the above rights, please contact the data Controller using the contact details indicated above. The abovementioned requests can by sent by e-mail to info@20200224verne.fastpages.pl, or by post to the address of Verne Legal provided in point nr.3.

4.5. Recruiting

As part of the recruitment processes, the Controller expects to be provided personal data (e.g. in a CV, CV or cover letter) only to the extent required by the applicable labour law. Therefore, no additional information should be provided. If the submitted applications contain additional data, they will not be used or included in the recruitment process.

5. COOKIES

Like most websites, Verne Legal uses cookies to help visitors use the website and to create anonymous statistics.

5.1. Definition

The concept of cookies should be understood in a broad sense. It includes IT data, in particular all markers used and / or read while browsing the Website, regardless of the type of device used (e.g. computer or smartphone).

Cookies make the website environment more suited to the needs of the User by:

      • Keeping preferences, so you don’t have to enter them every time you visit the Website,
      • Assessment of the Website usage and related needs, and then adapting the Website to the User’s expectations.

Our cookies are designed to improve the functioning of the Website from the User’s perspective.

They enable managing and / or deleting selected files. However, we would like to draw Users’ attention to the fact that blocking or limiting the use of cookies may affect some of the functionalities of the Websites and prevent the User from fully experiencing the services offered by the Website.

Cookies will not be used to collect personal data on the user’s hard drive, read e-mail addresses, or to obtain private information.

5.2. Cookie Settings

The User has a possibility to manage VL Website Cookies settings. He/she can disable them or limit them at any time, by changing the Web browser settings. The use of the Cookie settings varies on the browser. More information on how to change the cookie settings can be found in the browser’s help menu.

5.3. Use of cookies

This VL site uses cookies in many locations. Due to the lack of functions such as creating an account, a log in, commenting or shopping via WooCommerce, the Website does not use WordPress cookies.
However, the Website automatically collects User data and uses cookies for technical, marketing and analytical purposes. More precisely, this applies to cookies essential for the Site and acceptance of its use (so-called technical cookies), functionality cookies, statistics cookies, as well as marketing cookies (social media cookies included).

Please find below the list of cookies collected, as well as details concerning the reasons for their using and the time of their storage.

Technical cookies (cookies essential for the site)

Cookie name Purpose Expiration
eZSESSID This cookie is used by our content management system and is added when you visit the Site. It is essential for the functioning of the Website. It enables the user to navigate on the website and use Site functionalities. Session

Remembering information about VL Cookies Policy

During the User’s first visit, a Cookies notification message will appear, providing the User with the basic information on the use of cookies and asking for the acceptance. By clicking the “Accept” button, cookies will be saved, which will enable the User’s computer to receive the confirmation of reading the Cookie policy, to remember it and thus not to display it during the next visit.

Cookie name Purpose Expiration
VernelegalAcceptCookies It stores cookies to inform us that the User have seen and accepted our Cookie notification message. 12 months

Estimating and assessing the use of the website
We use Google Analytics to collect information about the use of the website and to better understand Users’ expectations. It enables us to constantly improve our Website.
Google Analytics stores information about websites visited by the User, the amount of time spent on them, etc. We do not collect or store any personal information, such as name or address, so this cookie cannot be used to identify you as a User. We do not allow Google to use or share the data of people who viewed our site to third parties.
You can opt out of Google Analytics cookies by visiting this page on Google.

Cookie name Purpose Expiration
_utma This randomly generated number is used to determine the number of unique Users on our Site. 13 months
_utmb This randomly generated number along with _utmc is used to calculate the average amount of time Users spend on our site. 30 minutes
_utmc Randomly generated number used (with _utmb) to calculate when you close your browser. Session
_utmz Randomly generated number and information about how the User accessed the Website (for example, via a direct link, by searching or paid search). 6 months
_jsuid This “cookie” stores a random number that is generated when you first visit the site. Its purpose is to identify new website Users. 13 months
_eventqueue This “cookie” stores a mapping of mouse movements that can be registered on our servers only when the current page is turned off. These offsets can not be processed until the next page is loaded. 1 hour
heatmaps_g2g_100626449 Thanks to this cookie we can order Google to record clicks on the page on the basis of which the heat map is created (record of website locations that the user watches and its duration). 1 hour
_first_pageview Session cookies set during the first preview of the Site at each visit. Its purpose is to check that certain parts of the code turn on at the first view of the page, speeding up its operation and improving efficiency. 10 minutes
_referrer_og This cookie stores user external credentials. 90 days

Cookies used for marketing purposes and on social networks
Hotjar

Cookie name Purpose Expiration
hjDonePolls Hotjar uses cookies and other technologies to collect data about the behaviour of Users and their devices (in particular the device’s IP address (captured and stored only in anonymous form), device screen size, device type (unique device identifiers), browser information, geographical location (country only), preferred language (used to display our website), click maps or other static charts, but also session recordings. Hotjar stores this information in a pseudonymous User profile. Neither Hotjar nor VL will ever use this information to identify individual users or to match them with further User’s data: https://www.hotjar.com/legal/policies/privacy 12 months
hjIncludeInSample Session

Double click

Cookie name Purpose Expiration
DSID – Double Click We use tools for advertising and re-marketing purposes. For this purpose, Google cookies are used for DoubleClick services (DoubleClick Campaign Manager, Doubleclick Bid Manager, DoubleClick Search, DoubleClick Floodlight). External suppliers install the appropriate code or pixel to download information about the User’s activity on the Services and then, on this basis, the User who visited our Services displays our ads on other websites belonging to the advertising network of our external suppliers (so-called remarketing), collects information about the campaig 15 days
IDE – Double Click 380 days

Social media

Cookie name Purpose Expiration
leo_auth_token These LinkedIn cookies are activated by the LinkedIn share button. They enable tracking of websites visited by the User. For more information, visit the LinkedIn page: https://www.linkedin.com/legal/privacy-policy 1 hour
L1e
metrics_token These are Twitter cookies. They are used by Twitter to provide embedded content that is displayed in the site. More information: https://help.twitter.com/en/rules-and-policies/twitter-cookies 1 hour
tfw_exp
6. HYPERLINKS TO OTHER WEBSITES

This Privacy and Cookies Policy applies exclusively to the VL Website.
As for other hyperlinks referring the User to other websites that are posted on the VL Website, VL disclaims all responsibility for the privacy practices of those websites. After entering the websites of other entities, we recommend that you read the Privacy Policy and Cookie Policy set out there.

7. CHANGES TO THE VERNE LEGAL PRIVACY AND COOKIES POLICY

From time to time, VL will update this Privacy and Cookie Policy to reflect changes in our practices and services. If we introduce changes to the content of this Privacy and Cookies Policy, we will change the “last updated date” at the bottom of the document. We recommend checking the content of this page on regular basis to be aware of the changes in the content of this document.

8. FINAL PROVISIONS

his Privacy and Cookies policy shall be governed by and construed in accordance with French law, in consideration with specific ethical and deontological rules. Any disputes that may arise from the relations covered by this policy are to be held, in case of inability to encounter an amiable solution, before the French Court territorially competent for the registered office of VERNE LEGAL.

Updated on November 8th, 2019
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