The Marie Claire Group (hereinafter “Marie Claire Group”), comprising Marie Claire Album SAS, a simplified joint-stock company with a capital of €4,347,640,  registered with the RCS of Nanterre under number 552 062 770 whose registered office is located at 9 Place Marie-Jeanne Bassot 92300 LEVALLOIS-PERRET, as well as its existing and future subsidiaries, is the publisher of content, products and services available on various media.   This Privacy Policy sets out the Marie Claire Group’s commitments regarding the protection of your personal data in your capacity as customers or Internet users, and as a user of the services. It informs you of the methods of collection and use of personal data concerning you, and the rights you have in this regard.   The Marie Claire Group complies with the law “Informatique et Libertés” n° 78 of January 6^th, 1978 amended, the law for the “Confidence and the Digital Economy” n° 2004 – 575 of June 21, 2004 as well as the European Regulation 2016/679 of April 27, 2016 (hereinafter the “Applicable Regulations”).
The Marie Claire Group has set up a Data Protection Officer in charge of ensuring the proper application of the Applicable Regulations and the respect of the rights you have in accordance with the said law.   The MARIE CLAIRE Group’s Privacy Policy applies in addition to the General Terms and Conditions of  Use and the General Terms and Conditions of Sale of the sites where they exist.  

I.  WHAT PERSONAL DATA IS COLLECTED ON OUR SITES AND WHY?

We collect declarative data as well as behavioral data (hereinafter taken together as “your Personal Data”). The data is collected in order to allow you to benefit from our products and/or services, to receive personalized information, to manage your orders, to offer you adapted commercial offers, to participate in marketing operations (competitions), to test a selection of products and, if necessary, to make you benefit  from offers from our partners. This data also allows our services to administer and improve our marketing activities and services to our readers. When collecting your personal data, you are warned of the mandatory or optional nature of the information requested, as well as the consequences of not providing data. In any case, you are informed of the treatments carried out, the rights you enjoy, and the means to exercise them. When we collect, process and store your data with your consent, you will have the opportunity to withdraw your consent at any time. However, you may not question the lawfulness of the processing carried out before the withdrawal.

Declarative data The Marie Claire Group collects the information that you voluntarily provide to us to benefit from the service of your choice. The data is thus collected when you register for one of our services, when you place an order or during any other marketing animation. These data are generally your identity and contact data (e.g. postal and/or e-mail address, telephone number) and may also be associated with various data (information related to the household, family, interests, etc.). You may be offered commercial offers from the Marie Claire Group  and/or its partners. The Marie Claire Sollic Groupwill then obtain your consent in accordance with the applicable regulations. All this data is stored in our customer database, in order to be able to communicate with you and propose offers tailored to your needs.

Behavioral data The behavioral data collected allows, during each of your visits, to carry out global statistical studies on the audience of our services, to identify you if necessary, to adapt the content of a service or an advertising offer to your behavioral data and, more generally, to study your behavior during your navigation on our sites  in order to offer you a better browsing experience and use of the services offered by the Marie Claire Group. You may also be asked  to respond to online surveys offered by the Marie Claire Group  because you are a customer and user of our products and/or services. These surveys and the data collected are anonymous.  We will only retain certain declarative behavioral data associated with your profile with your express consent.

Browsing data The Marie Claire Group is also likely to keep the events of interactions between you and the services of the MARIE CLAIRE Group  (page loads, button clicks, click rates on newsletters, banners etc …)  in orderto offer you offers tailored to your wishes, and generally improve our services according to the expectations of our customers.

Cookies A cookie is a small text file, stored on the hard drive of your computer at the request of the server managing the website visited. It contains information about the navigation carried out on the pages of this site and makes it easier to use the site later on your next visit. The information collected by a cookie can only be read by the issuer of the cookie. You can oppose the implementation of cookies, but in this case you risk having degraded access to the services offered. We therefore advise you to leave them active to fully enjoy our services and your browsing on our sites. For more information about cookies, we invite you to consult our cookie information page Data not collected directly from you: In certain cases, Personal Data about you may have been collected from third parties. Thus, the Marie Claire Group  may collect Personal Data from these partners. These sources are non-public. If necessary, we will not fail to provide you with all the information on the processing as well as any useful information regarding the exercise of your rights of opposition, erasure, limitation, access, rectification and portability.  

II.  HOW IS YOUR PERSONAL DATA USED BY GROUPE MARIE CLAIRE?

2.1. Declarative data

They may, if necessary with your consent by ticking the boxes provided for this purpose, be used by the Marie Claire Group (1 and 2) and/or  by its partners (3) and/or  by its service providers (4).
(1)  The declarative data is necessary to allow you   to create and manage your personal accounts, to register and manage your orders and subscriptions, or to access and use the services offered by the Marie Claire Group sites, to participate in marketing animation operations (competitions, product tests, etc.).   and other promotional activities. If you are a customer of a Marie Claire Group company, the same company may send you offers for products similar to those you have already ordered.
(2) If you have ticked the “Yes” box for the “Marie Claire Group” option, your declarative data may also be used by the Marie Claire Group to inform you of the news of its commercial activities. Data concerning your interests or the composition of your household may allow Groupe Marie Claire to make proposals tailored to your needs or interests.
(3) If you have ticked the “Yes” box for the “Partners” option, you may also receive communications and/or  commercial offers relating to products and/or services provided by our contractual partners.  They will then have your declarative data.
(4) Your declarative data may also be transmitted to service providers commissioned by the Marie Claire Group to ensure the effectiveness of the services you have ordered, for example to ensure deliveries.

2.2. Behavioral data

During your visits to the Marie Claire Group sites, cookies may be placed on your computer. The Marie Claire Group  complies with the CNIL’s recommendation of 5 December 2013 concerning cookies: – During your first visit to a site, a banner informs you of the installation of cookies, your right to oppose them and the procedure to follow to do so; – Are not concerned cookies that allow you to browse our sites and be identified during your next visit, or cookies allowing the realization of statistics of frequentation of our sites or to memorize your shopping cart.

2.3. Links to third-party sites and connection to social networks

Our websites and applications may contain links to websites belonging to our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these sites have their own privacy policies and that we are not responsible for these policies. We invite you to read the terms of these policies before sending any personal data to these websites. We can also offer you the opportunity to connect through your social networks. If you decide to do so, we would like to point out that you provide us with your profile information depending on the settings of the social networks you use. We invite you to visit the relevant social media and consult its personal data protection policy to understand how your data is shared and used in this context.

Social Media and User-Generated Content Some of our websites and apps allow users to upload their own content. We remind you that any content transmitted to one of the social networks we use may be publicly available. Therefore, we invite you to exercise caution with regard to the communication of certain personal data such as financial data or an address. We are not responsible for any actions taken by third parties in the event that you post personal data on one of our sites or applications, and we recommend that you do not provide this information.  

III. WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?

The Personal Data collected is intended for the Marie Claire Group and the departments and employees who need to know about it in order to achieve the purpose pursued. They may also be managed by the group’s advertising network with regard to advertising cookies and/or be transmitted to subcontracting companies expressly mandated by the group. Your Personal Data is only communicated to third parties  in the following cases:

• when you have given your prior consent for the sharing and/or disclosure of your Personal Data; Groupe Marie Claire does not share your Personal Data with third party advertisers for targeted marketing purposes unless you have previously consented to this.
• when the Marie Claire Group must share your Personal Data with its business partners,  and service providers, in order to achieve the purpose pursued.
• In particular, Marie Claire Group provides your Personal Data to third-party companies to provide services on its behalf, including processing payments and refunds, processing mailing campaigns, managing the information flows of subscriptions and resubscriptions, hosting services, processing certain marketing and logistical aspects   of the services or activities offered on our sites. .
• pursuant to a law, regulation or pursuant to a decision of a competent regulatory or judicial authority or, if necessary, in order to preserve its rights and interests, the Marie Claire Group  may communicate your data.
• in the event of a change of control  of the Marie Claire Group and its subsidiaries or the  sale of all or part of its assets, the Marie Claire Group  will be authorized to transfer your Personal Data.

Please note, however, that advertisers may obtain your Personal Data from other public sources. The Marie Claire Group  cannot in the same way be held liable in this respect. On the other hand, the Marie Claire Group  may use and share with third parties certain non-personal technical or aggregated data relating to your browsing on the Marie Claire Group sites. The collection, processing and disclosure of such anonymized data shall not be subject to the restrictions set forth herein.  

IV. HOW LONG IS YOUR PERSONAL DATA STORED?

The retention period of your Personal Data varies depending on the purpose of collection.  Personal Data is kept in accordance with the provisions of simplified standard No. 48 adopted by the CNIL. Legal obligations may require the Marie Claire Group to retain it for a minimum period. In other cases, the data concerning you will be kept within the limits of the achievement of the purpose pursued. Beyond that, the data will be kept for commercial prospecting purposes for a period of three (3) years from the last active event on your part. Where the processing is based on your consent, the data is kept until you withdraw your consent or request the deletion of your data. Data collected automatically such as browsing or connection data (e.g. cookies), as well as raw traffic data associating an identifier, will not be kept beyond thirteen months from the installation of the cookie in the user’s terminal. The data relating to bank cards are deleted as soon as the transaction is carried out (subscription to a subscription, purchase of an article on a fee-for-service basis, etc.). However, they are kept, in accordance with Article L.133.24 of the Monetary and Financial Code in the event of a transaction dispute, in intermediate archives, for a period of fifteen (15) months. Personal data is stored and kept for the duration during which the User keeps his Account on the Digital Media, is subscribed to the Company’s Newsletters, for the duration and processing of the competition. We may retain certain personal data in order to comply with our legal or regulatory obligations, and to enable us to exercise our rights (e.g. to bring an action in any court) or for statistical or historical purposes. We may also retain certain personal data in order to keep a suppression list up to date if you have requested not to be contacted;  

V. SECURITY OF PERSONAL DATA

5.1. The Marie Claire Group implements all technical and organizational means to guarantee the security of your personal data, and to prevent any risk of loss, deterioration or misuse thereof. Likewise, we limit access to personal data to employees whose duties require consultation of this data. Where we do not  or no longer need to use your personal data, we anonymize them so that they do not allow you to be identified or we delete them from our systems and files. 5.2. The login credentials allows you to identify yourself and log in to your device on some of our sites. These Login Credentials, created by you, are personal and confidential. You agree to keep your Login Credentials secret and you agree not to disclose them in any form whatsoever to third parties. Unless proven otherwise, any transaction made from your account shall be deemed to have been made by you. We invite you to explicitly log out at the end of each session. In the event of loss, theft or accidental disclosure of your login credentials, you must inform the company without delay by clicking on the dedicated link accessible “forgotten password”; You will then be prompted to create a new password. Any loss, theft, misappropriation or unauthorized use of the Login Credentials and their consequences are the responsibility of the user. Opening a new session with Login Credentials already in use will automatically close the 1st open session.  

VI. IS YOUR PERSONAL DATA TRANSFERRED ABROAD?

For the purpose of performing its services and, in particular, the management of subscription and resubscription information flows, and for these purposes only, the Marie Claire Group may transfer your Personal Data to subcontractors located outside the European Union (in this case, in Madagascar). We will implement the necessary means to ensure respect for your privacy and your Personal Data, in particular by the signature by each subcontractor of standard contractual clauses validated by the European Commission.  

VII. COOKIES

A Cookie allows its issuer, during its period of validity, to recognize the terminal concerned each time these terminal accesses digital content containing Cookies from the same issuer. Cookies do not keep any record of a user’s personal information and identifiable data will never be saved. The Marie Claire Group sites use cookies for a variety of reasons. In particular, they allow the Marie Claire Group to understand how users navigate our sites, and to obtain data from which we can improve the browsing experience in the future, to send you personalized offers, to identify you when you access your customer account, to keep items in your shopping cart after disconnection,  but also to indirectly finance the free services that we offer you and that are provided to you by our various sites. In accordance with the regulations in force regarding the protection of privacy on the Internet, in  particular the  Ordinance of 24 August 2011, the MARIE CLAIRE Group has, except in the legal exception, the obligation to seek your prior consent, which is valid for 13 months at most. Internet browser settings are usually set by default to accept cookies, but you can easily change this by changing your browser settings. Many cookies are used to improve the usability and functioning of websites/applications, so disabling cookies may prevent you from using certain parts of the sites. If you wish to restrict or block all cookies that are placed by our websites/applications (which may prevent you from using certain parts of the site), or by other websites/applications, you can do so by going to your browser settings. To learn more about cookies and their impact on your browsing  experience, you can consult the CNIL website, en or our Cookie Information page.  

VIII. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

In accordance with applicable regulations, you have the following rights:

1.     The right to be informed You have the right to obtain clear, transparent, understandable and easily accessible information about how we use your personal data and your rights. That is why we provide you with the information in this Policy.

2.     Access right You have the right to access the personal data we hold about you (subject to certain restrictions). Requests that are manifestly unfounded and excessive, in particular because of their repetitive nature, may not receive a reply.

3.     The right to rectification You have the right to demand that your personal data be rectified and/or completed if they are inaccurate or out of date and/or incomplete.

4.     The right to erasure/right to be forgotten In certain cases, you have the right to obtain erasure or deletion of your personal data. This is not an absolute right, as we may be obliged to retain your personal data for legal or legitimate reasons.

5.     The right to object to commercial prospecting, including profiling You may unsubscribe or object to the processing of your data at any time, unless it is based on compelling legitimate grounds, either by  clicking on the “unsubscribe” link in any email or communication we send you, or by contacting us using the contact details below.

6.     The right to withdraw the consent given, at any time You may withdraw your consent to the processing of your data when it is based on consent. However, the withdrawal of this consent does not affect the lawfulness of the processing carried out before its withdrawal.

7.     The right to data portability You have the right, within the limits of the technical processes used by the Marie Claire Group, to request to receive your personal data, in a structured, commonly used and machine-readable format, and that they be transmitted to another controller, for processing carried out by automated means for which you have given your consent.

8.     The right to restriction of processing You have the right to request the restriction of the processing we carry out on data concerning you.

This right means that the processing of data about you by us is restricted, so that we may retain this data, but not use or process it. This right applies in specific circumstances provided for by the General Data Protection Regulation, namely:
·       the accuracy of the personal data is contested by the data subject (i.e. you), for a period allowing the controller to verify the accuracy of the personal data;
·       the processing is unlawful and the data subject (i.e. you) opposes its erasure and instead demands the restriction of its use;
·       the controller (i.e. the Marie Claire Group) no longer needs the personal data for the purposes of the processing but they are still necessary for the data subject to establish, exercise or defend legal claims;
·       the data subject (i.e. you) has objected to processing based on the legitimate interests pursued by the controller during the verification of whether the legitimate grounds pursued by the controller override those of the data subject.

9 – Exercise of rights

If you have an account, we invite you to modify your personal data  via this space. For any requests, you can send an e-mail or mail  to the address indicated during the collection or to the address below, attaching a photocopy of an identity document bearing your signature: Marie Claire Group Data Protection Officer 9 Place Marie-Jeanne Bassot 92300 LEVALLOIS-PERRET [email protected] The Marie Claire Group will have a period of 1 (one) month to respond following receipt of your request. If necessary, this period may be extended by two months, taking into account the complexity and number of requests. In the event that the MARIE CLAIRE Group is informed of your death, this information will be indicated on our files so that no more prospecting is sent. Your data will then be purged.  You can also communicate your instructions by contacting us at the above address.

10 – Complaints

You also have the  right to lodge a complaint with the data protection authority (the CNIL) to challenge Groupe Marie Claire’s practices regarding the protection of personal data and respect for privacy.

11 – Telephone canvassing

In addition, in accordance with Law No. 2014-344 of 17 March 2014 on consumption, you can oppose telephone canvassing by registering on the national opposition list “Bloctel”: https://conso.bloctel.fr. The MARIE CLAIRE Group nevertheless informs you that the law allows you to be called if: – You are our customer; – You have given your number unequivocally: we will then be able to contact you within 3 months from the date of communication of your telephone number. – The telephone call consists in offering you the supply of newspapers, periodicals, or magazines or to contribute to a charitable action carried out by a non-profit association. More information about your rights https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles