Update : 22 03 2022
Through this document, the company TEMO SAS (referred to as TEMO or "we") wishes to inform Internet users consulting our websites about the purpose, nature and scope of the processing of personal data concerning them. According to the GDPR General Data Protection Regulations, the person in charge of data processing on our website is the company TEMO, 2, rue Alfred Kastler, 44300 Nantes ([email protected]).
Our websites and services are subject to constant redesign and development. Consequently, the present information on data confidentiality is regularly modified and updated. This applies in particular to the procedures we implement to analyse the use and evaluate the effectiveness of advertising methods and comparable services, especially those of third party providers. The current version is indicated at the very top of this paragraph.
A few words beforehand concerning the use of service providers outside the European Union: TEMO is a company offering products and services on an international level. It therefore extends beyond the borders of France and the European Union. We operate worldwide and supply customers in the four corners of the globe. We are happy to call upon European service providers for certain services or performances, if they are able to offer us the necessary services at a comparable level of quality and price. However, we prefer to be honest: unfortunately, there is no comparable alternative for some of the services we use. Therefore, we use a few service providers based outside the European Union, particularly in the USA (e.g. Google Analytics). In order to ensure an appropriate level of data protection, we make sure that we take all the measures required by European data protection legislation.
TEMO's privacy charter is based on the terms used by the European legislator issuing directives and the provisions of the General Regulation on the Protection of Personal Data (RGPD). Our confidentiality charter is available to both the public and our customers and must be easily readable and understandable. For these purposes, a few definitions are given below.
a) Personal data
Personal data" shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an "identifiable natural person" is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an on-line identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.
b) Data subject
Data subject" shall mean any identified or identifiable natural person whose personal data are processed by the controller.
Processing" shall mean any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, limiting, erasure or destruction.
d) Limitation of processing
Limitation of processing" means the marking of stored personal data with a view to limiting their further processing.
e) Controller or person in charge of processing
Controller or controller" shall mean the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union law or the law of a Member State, the controller may be designated or the specific criteria for its designation may be laid down by Union law or the law of a Member State.
Processor" shall mean the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient" shall mean the natural or legal person, public authority, agency or any other body which receives communication of personal data, whether or not it is a third party. However, public authorities which may receive personal data in the course of a particular inquiry pursuant to Union law or the law of a Member State shall not be regarded as recipients.
h) Third parties
Third party" shall mean a natural or legal person, public authority, service or body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorised to process personal data.
Pseudonymisation" shall mean the processing of personal data in such a way that they can no longer be attributed to a specific data subject without recourse to additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that personal data are not attributed to an identified or identifiable natural person.
Profiling" shall mean any form of automatic processing of personal data which involves the use of personal data to evaluate certain personal aspects relating to a natural person, in particular for the purpose of analysing or predicting matters concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, conduct, location or movements.
Consent" of the data subject shall mean any freely given, specific, informed and unambiguous expression of his or her wishes by which the data subject signifies his or her agreement, by a declaration or a clear positive act, to personal data relating to him or her being processed.
2. Nom et adresse du responsable du traitement
Responsable au sens défini par le Règlement général sur la protection des données personnelles, les lois en vigueur dans les États membres de l’Union européenne et autres dispositions relatives à la protection des données est la société :
17 Rue Daniel Gillard - 56000 VANNES - FRANCE
M: 33(0)9 70 70 38 80
E-Mail: [email protected]
The TEMO website uses text files (called "Cookies") which are recorded and stored in a computer system through a web browser.
Legal basis :
lThe data collection is based on consent via the cookie banner pursuant to Article 6(1)(a) of the GDMP, or alternatively, on necessity for the legitimate interests pursued by the controller pursuant to Article 6(1)(f) of the GDMP.
Possibility of objection:
The person concerned may at any time deactivate the deposit of cookies by our site by selecting the appropriate parameters of his browser and thus permanently oppose the registration of cookies. He or she also has the possibility of deleting cookies previously deposited by a browser or other software. All current browsers offer these options. However, the deactivation of cookies in the browser of the person concerned can possibly limit certain functions of this site.
4. 4. Collection of data and general information
The TEMO website collects a certain amount of data and general information each time a person concerned or an automatic system consults a page of the site. This data and general information is recorded in the server log files (.log). These data can be the following:
- the type and version of the browser ;
- operating system used by the requesting system;
- the site from which the requesting system accesses our page (the "referrer" site);
- the sub-pages that a requesting system accesses from our site;
- the time and date the page was accessed;
- the Internet Protocol (IP) address;
- the Internet service provider of the requesting system, and other similar data and information in order to be able to detect attacks on our computer systems.
TEMO does not derive any information about the person concerned from this general information, but uses this data necessary to
- correctly provide the contents of its site ;
- to optimize the contents and the possible advertisements of its site; ensure the sustainable operation of its IT systems and technical processes on our site;
- be able to provide the necessary information to law enforcement agencies in the event of a cyber attack.
Consequently, TEMO evaluates the data and information collected on the one hand for statistical purposes and on the other hand to increase data protection and security within the company and to guarantee a maximum level of protection for the personal data processed. Anonymous data from the server log files are stored separately from the personal data indicated by a data subject..
Legal basis :
The data collection is based on necessity for the legitimate interests pursued by the controller pursuant to Article 6(1)(f) of the GDPR.
Possibility of objection :
As these data are indispensable for the functioning of the site, the user cannot object to their collection.
5. Registration on our website
It is possible to register on the TEMO website by entering certain personal data. The personal data transmitted to the data controller during this process are the data entered in the registration mask. The personal data entered is only collected and stored with the data controller for internal and own purposes. The controller may initiate the transmission of the personal data to one or more processors, for example a parcel delivery company, which also only uses the personal data for internal purposes attributable to the controller.
When registering on the website, the system also records the IP address assigned to the data subject by the Internet Service Provider (ISP) as well as the date and time of registration. The recording of this data is the only way to prevent misuse of our services and, if necessary, to be able to pass on this data to the competent authorities in the event of a criminal offence. In this sense, the recording of this data is necessary for the protection of the data controller. This data is not passed on to third parties unless there is a legal obligation to do so or unless it is passed on for the purposes of criminal prosecution
Legal basis :
The data collection is based on necessity for the purposes of the legitimate interests pursued by the controller pursuant to Article 6(1)(f) of the GDPR.
Possibility of objection :
As these data are essential for the functioning of the site, the user cannot object to their collection.
The registration of the data subject and the voluntary input of his/her personal data allows the data controller to offer him/her content or services which, by their nature, can only be offered to registered users. Registered users can correct the data entered during registration at any time or have them completely deleted from the data controller's database.
Legal basis :
The data collection is based on the consent of the data subject pursuant to Article 6(1)(a) of the GDPR).)
Possibility of objection:
The users concerned may have their registration and data erased by sending a simple request by e-mail to: [email protected]
6. Newsletter subscription
Users of the TEMO website have the possibility to subscribe to our company's newsletters. The personal data transmitted to the data controller during this process are the ones filled in the subscription mask.
Only the persons concerned (1) with a valid e-mail address and (2) having subscribed to the corresponding subscription or customers having subscribed to one of our offers can receive the newsletters.
When registering, we also record the IP address assigned by the Internet Service Provider (ISP) to the computer used by the person concerned at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace any (possible) misuse of a data subject's e-mail address at a later date and serves as legal protection for the data controller.
The personal data collected in the context of a registration is used exclusively for the distribution of newsletters. In addition, subscribers may receive information by e-mail insofar as this is necessary for the operation of the service or if a registration is required, e.g. in the case of changes to the offer or the technical context. The personal data collected is not passed on to third parties. The data subject can revoke the collection of information at any time. The data subject may withdraw his or her consent to the recording of personal data at any time. Each newsletter contains a revocation link to this effect.
7. Tracking in newsletters
TEMO's newsletters contain web beacons. A spy pixel or tracking pixel is a very small graphic inserted in emails sent in html format to capture information recorded in a log file or to analyze such a file. This makes it possible to perform statistical analysis to evaluate the success or failure of online marketing campaigns. The web beacon placed in the e-mail allows TEMO to see if and when the person concerned opened an e-mail and which links were clicked on in the e-mail.
The personal data collected via the web beacons is recorded and analysed by the data controller with the aim of optimising the sending of information and adapting the content to the interests of the data subject in the best possible way. These personal data are not passed on to third parties. Data subjects are entitled at any time to revoke the consent given in the double confirmation e-mail (double opt-in method). Following this revocation, the data subjects are removed from the mailing list by the controller.
8. Contact on the website
In accordance with the legal requirements, the TEMO website contains information that enables quick contact and direct communication with our company by electronic means. As soon as a data subject contacts the data controller, e.g. by email or via a contact form, the personal data of the data subject is automatically recorded. This personal data, which is transmitted voluntarily to the data controller, is recorded exclusively for the purpose of processing the request or contacting the data subject. These personal data shall not be transmitted to third parties.
Legal basis :
The processing of contact data is based on the consent of the data subject pursuant to Article 6(1)(a) of the PGRD.
9. Automatic deletion and blocking of personal data
The controller shall process and record the personal data of the data subject only for the time necessary to achieve the purposes of the retention or unless the retention of personal data is provided for by the European legislator issuing the Directives and provisions or in laws or regulations of another legislator to which the controller is subject.
Personal data shall be automatically blocked or deleted as soon as the purposes for which they are stored no longer exist or as soon as the storage period provided for by the European legislator issuing the directives and provisions or by another competent legislator has expired.
10. Rights of the data subject
a) Right of confirmation
Any data subject shall have the right to obtain confirmation from the controller that personal data relating to him or her are or are not being processed. A data subject wishing to exercise his right of confirmation may contact the staff of the controller at any time.
b) Right of information
Any person concerned by the processing of personal data shall have the right to obtain at any time and free of charge from the controller access to and a copy of the personal data concerning him/her. In addition, the European legislator issuing the Directives and provisions has granted the data subject the right of access to the following information:
- the purposes of the processing operation ;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients established in third countries or international organisations
- where possible, the envisaged period of storage of the personal data or, where this is not possible,
- the criteria used to determine this duration ;
- the existence of the right to request the controller to rectify or erase personal data, or to restrict or oppose the processing of personal data relating to the data subject;
- the right to lodge a complaint with a supervisory authority ;
- where the personal data have not been obtained from the data subject: any available information as to their source ;
- the existence of automated decision making, including profiling, as referred to in Article 22(1) and (4) of the PDSR and, at least in such cases, relevant information as to the underlying logic, significance and intended consequences of the processing for the data subject
Furthermore, every data subject has the right to be informed about the transfer of his personal data to a third country or an international organisation. When personal data are transferred to a third country or to an international organisation, the data subject shall furthermore have the right to be informed of the appropriate safeguards with regard to such transfer.
The data subject wishing to exercise his or her right of information may contact the staff of the controller at any time.
c) Right of rectification
Any person concerned has the right to obtain as soon as possible the rectification of inaccurate personal data concerning him/her. Having regard to the purposes of the processing operation, the data subject has the right to obtain the completion of incomplete personal data, including by providing an additional declaration. The data subject wishing to exercise his/her right of rectification may contact the staff of the controller at any time.
d) Right to limit processing
Any data subject shall have the right to obtain from the controller the restriction of the processing where one of the following applies :
- the accuracy of the personal data is contested by the data subject, for a period of time allowing the controller to verify the accuracy of the personal data ;
- the processing is unlawful and the data subject objects to their erasure and instead requires the restriction of their use ;
- the controller no longer needs the personal data for the purpose of processing but they are still necessary for the data subject to establish, exercise or defend legal claims ;
- the data subject has objected to the processing on the basis of Article 21(1) of the RGDP during the verification as to whether the legitimate grounds pursued by the controller prevail over those of the data subject.
If either of the above conditions is met, any data subject wishing to request the restriction of personal data recorded with TEMO may contact the staff of the controller at any time. TEMO's staff will take the necessary steps to limit the processing of the data.
e) Right of opposition
Any data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her on the basis of Article 6(1)(e) or (f) of the PDSR, including profiling based on those provisions.
If the data subject exercises his right to object, TEMO shall no longer process personal data, unless the data subject demonstrates that there are legitimate and compelling reasons for the processing which override the interests, rights and freedoms of the data subject, or for establishing, exercising or defending legal claims.
Where TEMO processes personal data for the purposes of canvassing, the data subject shall have the right to object at any time to the processing of personal data relating to him for such canvassing purposes, including profiling insofar as it is related to such canvassing. When the data subject exercises his/her right to object to the processing for canvassing purposes by TEMO, TEMO will no longer process personal data for such purposes.
Where personal data are processed by TEMO for scientific or historical research or statistical purposes pursuant to Article 89(1) of the GDMPR, the data subject shall have the right to object, on grounds relating to his or her particular situation, to the processing of personal data relating to him or her, unless the processing is necessary for the performance of a task carried out in the public interest.
Any data subject wishing to exercise his/her right to object may contact TEMO's staff or another employee directly. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may also exercise his right to object by means of automated processes using technical specifications.
f) Right to erasure ("right to forget")
The data subject shall have the right to obtain from the controller the erasure, as soon as possible, of personal data relating to him or her where one of the following grounds applies and insofar as processing is not necessary :
the personal data are no longer necessary for the purposes for which they were collected or otherwise processed ;
- the data subject withdraws the consent on which the processing is based, in accordance with Article 6(1)(a) of the PDSR or Article 9(2)(a) of the PDSR, and there is no further legal basis for the processing ;
- the data subject objects to the processing on the basis of Article 21(1) of the GDMPR and there are no compelling legitimate grounds for the processing, or the data subject objects to the processing on the basis of Article 21(2) of the GDMPR ;
- the personal data have been processed unlawfully ;
- the personal data must be erased in order to comply with a legal obligation under Union law or the law of the Member State to which the controller is subject ;
- the personal data have been collected in the context of the provision of information society services as referred to in Article 8(1) of the PDSR.
If any of the above grounds apply, any data subject wishing to request the erasure of personal data recorded with the TEMO company may contact the staff of the controller at any time. TEMO's staff will take the necessary steps to ensure that the request for deletion is processed as soon as possible.
Where TEMO Company has made personal data public and is under an obligation to erase them pursuant to Article 17(1) of the PGRD, TEMO Company, taking into account the available technologies and the costs of implementation, shall take reasonable measures, including technical measures, to inform the data controllers processing such personal data that the data subject has requested the erasure by such data controllers of any link to, or any copy or reproduction of, such personal data, provided that such processing is not necessary. TEMO's staff will take the necessary steps to respond to the data subject's request on a case-by-case basis.
g) Right to data portability
Any person concerned by the processing of personal data shall have the right to receive personal data relating to him or her which he or she has supplied to a controller in a structured, commonly used and machine-readable format and shall have the right to transfer such data to another controller without interference from the controller to whom the personal data have been disclosed, where the processing is based on consent pursuant to Article 6(1)(a) of the RPMR or Article 9(2)(a) of the RPMR or on a contract pursuant to Article 6(1)(b) of the RPMR and the processing is carried out by automated means. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Where the data subject exercises his right to data portability pursuant to Article 20(1) of the PGRD, he shall have the right to obtain the direct transmission of personal data from one controller to another, where this is technically possible and insofar as this right does not adversely affect the rights and freedoms of others.
Any data subject wishing to exercise his right of portability may contact the staff of the company TEMO at any time.
h) Automated individual decision making, including profiling
Any data subject shall have the right not to be subject to a decision based exclusively on automated processing, including profiling, producing legal effects concerning him or her or significantly affecting him or her in a similar way, insofar as the decision (1 ) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorised by Union law or the law of the Member State to which the controller is subject and which also provides for appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is based on the explicit consent of the data subject.)
Where the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is based on the explicit consent of the data subject, TEMO shall implement appropriate measures to safeguard the rights and freedoms and the legitimate interests of the data subject, at least the right of the data subject to obtain humane intervention by the controller, to express his or her views and to challenge the decision.
The data subject wishing to exercise automated individual decision-making rights may contact the staff of the controller at any time.
i) Droit de révocation du consentement au traitement des données personnelles
Right to revoke consent to the processing of personal data
Any data subject may revoke his or her consent to the processing of personal data concerning him or her.
A data subject wishing to exercise his or her right of revocation may contact the staff of the controller at any time.
11. Plugins and tools
a) Using Google Analytics
The data controller has integrated the Google Analytics component (with anonymisation function) into this website. Google Analytics is a website analysis service, which collects, collates and analyses data on the behaviour of website visitors. Among other things, a site analysis service records information on the website (referrer) from which a person concerned has accessed another website, on which subpages of the website have been visited or on the frequency and duration of visits to a subpage. The main goals of a site analysis are site optimisation and cost-benefit analysis of online advertising.
Google-Analytics is a service of Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The purpose of the Google Analytics component is to analyze the traffic of visitors to our site. Google uses the data and information thus collected for the purpose of evaluating the use of our website, compiling reports on website activity and providing other services related to the use of our website.
Google Analytics places a cookie on the computer system of the person concerned. See details above. The deposit of this cookie enables Google to analyse the use of our website. Each time the data subject visits one of the pages of this website managed by the data controller and on which a Google Analytics component has been integrated, the browser installed on his computer system is automatically instructed by the Google Analytics component to transmit data for the purpose of online audience analysis by Google. As part of this technical process, Google receives personal data, such as the IP address of the person concerned, which can be used, among other things, to trace the origin of the visitor and clicks and thus to charge commissions.
The deposited cookie records personal information, such as the time of access, the place from which access was gained and the frequency of visits to our website by the person concerned. With each visit to our website, the personal data of the person concerned, including the IP address of the Internet connection used by the person concerned, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may also transfer this personal data collected in the technical process to third parties.
You can prevent the storage of cookies by selecting the appropriate option on your browser software; please note, however, that this may limit certain functions of this website.
You also have the option of blocking the transmission and processing of the information collected by the cookie about your use of the website (including your IP address) by downloading and installing the following module in your browser: tools.google.com.
You can block the storage of the data collected for Google Analytics by clicking on the following link. An opt-out cookie placed on your computer will prevent the collection of your data during your visit to this website in the future..
Further information on the conditions of use and data protection can be found on the Google website www.google.com www.google.de/intl/de/policies or at www.google.de/intl/de/policies/.
b)Using the SendinBlue Newsletter tool
On our website we use the following social media buttons:
- Twitter, Twitter Inc. 1355 Market St, Suite 900, San Francisco, CA 94103, USA
- Facebook, Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA
- YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA.
Google+, Google Inc. 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
Instagram, 1 Hacker Way, Building 14 First Floor Menlo Park, CA.
Linkedin, LINKEDIN FRANCE SAS 519059281 (Paris 8e Arrondissement - 75008)
These social media buttons only provide links to the respective providers. As long as you do not click on any of these buttons, no data will be transmitted to these providers.
Twitter : http://twitter.com/privacy
Facebook : http://www.facebook.com/about/privacy
YouTube : http://www.youtube.com/t/privacy_at_YouTube
Google : https://policies.google.com/privacy?hl=en
Instagram : https://help.instagram.com/519522125107875
Linkedin : https://www.linkedin.com/legal/privacy-policy
15. Additional Information
Your trust is important to us. We are always ready to listen to you and answer your questions about the processing of your personal data at any time. If this data protection charter does not answer all your questions or if you would like more information one day, you can contact TEMO's data protection officer.
16. Contact the Data Protection Officer
2 RUE ALFRED KASTLER
Tel. +33(0)2 85 52 26 42
E-mail: [email protected]
Any Question? Contact-us!