Confidentiality of Bayard Group
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1. Who is responsible of the processing ?
Bayard Presse SA, a Public Limited Company governed by a Management Board and a Supervisory Board with a share capital of €16,500,000, its registered office at 18 rue Barbès, 92120 Montrouge, along with its subsidiaries, and in particular Bayard Editions, Milan Presse, Editions Milan, Bayard Média Développement, Notrefamille.com, Bayard Services, hereinafter jointly referred to as “Bayard Group” provides content, products and services through various online platforms.
This Confidentiality Policy details Bayard Group’s commitments regarding the protection of your personal data as customer or web visitor and service user. It sets out how your personal data is collected and used and your rights in this respect.
Bayard Group complies with the French Data Protection Act, no. 78 of 6 January 1978 as amended, the French “Trust and the Digital Economy” Act, no. 2004 – 575 of 21 June 2004 as well as Regulation 2016/679 of 27 April 2016.
Bayard Group has appointed a Data Protection Officer who is responsible for properly applying the law and ensuring your rights to access, rectify, object, erase, restrict and portability created by said law (firstname.lastname@example.org).
Bayard Group’s Confidentiality Policy applies on top of the General Terms and Conditions of Usage and General Terms and Conditions of Sale of websites where they exist.
2. What personal data is collected on our websites and why ?
As Data controller under the French Data Protection Act, Bayard Group is responsible for the personal data it collects.
The data is collected to allow you, as client, prospect or ordinary user of our services, to receive personalised information, to manage your orders, to offer you tailored commercial offers, and where applicable to pass on offers from our partners. This data also allows our departments to run and improve our marketing activities and services for our clients.
When collecting your personal data, you are advised when the requested information is required, in order to be able to enjoy a service, and when it is optional, as well as of the consequences of not providing us with a particular piece of information. You are also informed of how Bayard Group will use your data, of your right to access, rectify, object, erase, data portability and processing restrictions.Self-reported data :
Bayard Group collects the data needed to use the service of your choice, or to manage your order. The data collected for this purpose may include: your first names and surnames, your postal address, your email address, your telephone number. This may be supplemented by information on your household (number and age of children, areas of interest).
You may also be asked if you would like to receive commercial offers from Bayard Group or its partners. Pursuant to the French “Trust and the Digital Economy” Act, you must clearly express your consent by ticking a box confirming your agreement, as the case may be. You will of course be able to change your mind at any time and exercise your rights to object, erase or restrict. However, you cannot call into question the legality of the processing prior to the removal.
All this data is stored in our customer database, in order to communicate with you and tailor offerings to your needs.
Behavioural data : you may fill out online surveys run by Bayard Group because you are a customer and user of products or services. Such surveys are anonymous. However, we may ask for your agreement to keep some self-reported behavioural data that is linked to your customer account. In such circumstances, we therefore keep this data with your agreement. You are then advised of your rights to access, rectify, erase and object and how to exercise them.
We may also retain any interactions you have with Bayard Group services (page loads, button clicks, click rates on newsletters, banners etc…) in order to provide tailored offerings, and in general improve our services in line with customer expectations. In such circumstances, we therefore keep this data with your agreement. You are then advised of your rights to access, rectify, object and erase, data portability and processing restrictions, and how to exercise them.
Cookies : a cookie is a small text file stored on your computer’s hard disk at the request of the server running the Website visited. It contains information on browsing history on this website and facilitates subsequent usage of the website the next time you visit. The information collected by a cookie can only be read by the party creating it. You can refuse to store cookies, but should you do so you may have reduced access to the services on offer (see Chapter IV).Data not collected directly from you :
In certain instances, your Personal Data may have been collected from third parties. Accordingly, Bayard Group may collect Personal Data from these partners. These sources are not public. Where necessary, we will certainly provide you with full information on the processing as well as all necessary information on how to exercise your right to object, erase, restrict, access, rectify and portability.
If you create an account on one of our websites on behalf of your child in your capacity as parental authority, you are informed that personal data concerning your child under the age of 15 will be processed and used by Bayard Group in accordance with this confidential policy.
3. How does Bayard Group use your personal data ?
Self-reported data is required in order to record and manage your orders and use the services offered by Bayard Group websites.
Data on your areas of interest or the make-up of your household may allow Bayard Group to make tailored offerings.
Your email address may be used in the following manner:
- If you are a customer of a Bayard Group company, that company may offer you similar products to those you have already ordered.
- When collecting your email address, or at some later point, you may be asked to tick a box confirming you agree to receive commercial offers from Bayard Group. If you agree to tick this box, Bayard Group may email you offers for products it markets.
- Similarly, you may elect to receive offers from Bayard Group partners by ticking the appropriate box. If you agree, Bayard Group partners may email you commercial offers.
In any event, you may opt out of receiving commercial offers by email :
- By using the unsubscritpion link you will find at the bottom of any Bayard Group commercial emailing.
- By sending a letter to this following adress : Bayard (CNIL), TSA 10065, 59714 Lille Cedex 9.
- By writting an email to our DPO to this following adress : email@example.com.
Moreover, in accordance with French Act 2014-344 of 17 March 2014 on consumer affairs, you can opt out of cold-calling by adding your number to the national “Bloctel” opt-out list: https://conso.bloctel.fr.
Bayard Group would, nevertheless, like to inform you that there are exceptions. In fact, by law you can be called if:
- You are our customer;
- You freely shared your telephone number: we can then contact you within a period of 3 months from the date on which your telephone number was communicated.
- The call is to offer to send you newspapers, periodicals or magazines or to support the work of some charity.
Should Bayard Group be notified of your death, this information will be recorded in our files so that no further marketing materials are sent. Your data will then be deleted.
When you visit Bayard Group websites, cookies may be stored on your computer. Bayard Group complies with the CNIL (French Data Protection Authority) recommendation dated 5 December 2013 on cookies:
- When you first visit a website, a banner informs you that cookies will be stored, of your right to object and the steps you need to take to do so
- This does not cover cookies that allow you to browse our websites and be identified the next time you visit, or indeed cookies used for traffic statistic purposes or indeed to store the contents of your basket.
Pursuant to current regulations, behavioural data may be sent to the relevant authorities upon request.
Security of personal data
Bayard Group uses all technical means to ensure the security of your personal data, and to prevent any risk of loss, deterioration or improper use thereof.
4. Who receives your personal data ?
The personal data is for Bayard group and its subsidiaries.
Your Personal Data is not communicated to third parties, except in the following instances:
- When you have already agreed to share and/or disclose your Personal Data, including via functionality offered by Bayard Group websites;
- When Bayard Group is required to share your Personal Data with commercial partners (as authorised by you), suppliers, service providers and in particular technical service providers in order to provide services, resolve operational problems with services or indeed to offer advertising or promotional information connected with the services offered by Bayard Group;
- Bayard Group specifically shares your Personal Data with third party companies to provide services on its behalf, including payment processing, data analysis, handling mailing campaigns, management of information on subscriptions and subscription renewals, hosting of services, handling of certain marketing aspects of services;
- Where required by law, regulation or order of a competent regulatory or judicial authority or indeed, should it prove necessary, to protect its rights and interests, Bayard Group may share your data;
- In the event of a change of control at Bayard Group and its subsidiaries or the disposal of some or all of its assets, Bayard Group will be permitted to transfer your Personal Data;
Bayard Group does not share your Personal Data with third party advertisers for the purposes of targeted marketing unless you have already consented. It should, however, be noted that advertisers may obtain your Personal Data from other public sources. Bayard Group may not be held liable in this regard.
However, Bayard Group may use and share with third parties certain technical or non-personal aggregate data regarding your browsing on Bayard Group websites. The collection, processing and disclosure of such anonymised data shall not be subject to the restrictions set out herein.
5. How long is your personal data stored ?
The period of time for which your Personal Data is retained may differ depending on the purpose for which it was collected.
Bayard Group may be required by law to retain certain information for a minimum period. In other cases, your data will only be retained to complete the intended purpose (in this scenario, for the period strictly necessary for the management of the commercial relationship, namely seven years from the date on which Personal Data is collected), or in line with applicable regulations.
The information stored on your device (e.g.: cookies), or any other item used to identify you and allowing its traceability as well as raw traffic data containing an ID, will not be retained for more than thirteen months.
6. Will your personal data be transfered abroad ?
In order to deliver its services and in particular to manage information on subscriptions and subscription renewals, Bayard Group may transfer, purely for these purposes, your Personal Data to sub-contractors based outside the European Union (specifically in Morocco and Madagascar). To ensure your privacy and Personal Data are respected, the sub-contractors in question sign up to standard contractual clauses approved by the European Commission.
A cookie is a text file that stores information on your web browsing. This file, served by a server when you visit a website, is saved on the user’s hard disk and cannot either contain a virus or be executed. It isn’t running. Moreover, you can read it, delete it or change it. A cookie cannot be used to retrieve personal data from your hard disk, read your email address or obtain personal information.
Pursuant to the Order of 24 August 2011 on the application of European directives on the protection of online privacy, a cookie cannot be stored on your computer without your prior consent (except where permitted by law). BAYARD Group is thus obliged to get your prior consent, which is valid for at most 13 months. Some cookies are, however, exempt from this requirement of consent :
- The cookie is used for the sole purpose of carrying out the transmission of a communication, and;
- The cookie strictly necessary in order for the provider of an information society service explicitly required by the user to provide that service.
You have a number of options for managing Cookies, accepting or refusing them. You can:
- Configure your browser as you see fit (i);
- In the case of advertising cookies, use a system developed by the Internet advertising industry (ii);
- In the case of analytical cookies, you can refuse them by clicking on a simple link (iii)
- In the case of cookies created by Bayard Group, you can refuse them using the simple and accessible process detailed below (iii);
- Study the confidentiality policy on the social media platform you use, and thereby manage the storage of cookies from that social media platform (iv).
Most browsers accept cookies by default. You can, however, decide to block these cookies or ask your browser to alert you when a website attempts to store a cookie on your device. With that in mind, we hereby inform you that you can configure your browser to block cookies being stored. Each browser manages cookies and your preferences in a different way. Use the help menu on your browser to learn how to modify your cookie preferences.
Safari : https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=fr_FR
Opera : http://help.opera.com/Windows/10.20/fr/cookies.html
Chrome : https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en
Internet explorer : http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
FireFox : https://support.mozilla.org/fr/kb/activer-desactiver-cookies?redirectlocale=fr&redirectslug=Activer+et+d%C3%A9sactiver+les+cookies
The “Youronlinechoices” platform, funded by the Internet advertising industry in the form of the European Digital Advertising Alliance (EDAA) and managed in France by Interactive Advertising Bureau France, allows you to refuse or accept the Cookies used by member companies to tailor the adverts you may see on your device to your browsing information: http://www.youronlinechoices.com/uk/.
Please note, your preferences will not stop adverts being displayed but will block technologies designed to tailor advertising to your areas of interest.iii. Share your preferences with Bayard Group
When you visit our sites and you have not consented to cookies being stored during the 13 months preceding your visit, a banner appears and asks you to consent to cookies being stored. Following your express agreement, cookies are stored to enable optimal access to the website. For example, cookies make it possible to identify you and allow you to access your customer account. Please note, however, that regardless of whether you accepted or refused cookies, your preference can only be recorded if you use the same browser and have not deleted your browsing history in the meantime.iv. By directly refusing at the party creating this cookie in the case of analytical cookies or cookies used by social media platforms
- Analytical cookies
Bayard Group uses two systems designed in particular to measure traffic on its websites.
In the case of AT INTERNET (xiti)an “opt-out” option developed by AT Internet allows you to refuse to be audited and require that your browsing data be excluded from the data compiled by AT Internet. To activate this option, you must first accept the opt-out cookie from AT Internet. This acceptance ensures that your deactivation request will be acknowledged and recorded every time you visit websites audited by AT Internet. This option will only work in the browser in which the opt-out cookie is stored. http://www.xiti.com/en/optout.aspx
Lastly, with respect to Google Analytics, if you do not want this system to collect or use your information, you can unsubscribe at this page: https://tools.google.com/dlpage/gaoptout?hl=en
You can also deactivate the Google Analytics advertising functionality, using the Network Advertising Initiative opt-out page at this address: http://www.networkadvertising.org/choices/
- Social media platform cookie
To review the purpose and scope of the data collection, processing and use of data by the social media platforms you have joined, along with your rights and options to change preferences to protect your privacy, we would encourage you to check out their Cookie management policies on their websites.
- Facebook : http://www.facebook.com/about/privacy/
- Google+ : http://www.google.com/intl/it/policies/privacy/
- Twitter : http://twitter.com/privacy
- Instagram : https://instagram.com/legal/cookies/
- YouTube : https://www.youtube.com/static?template=privacy_guidelines
In order to give you an overview of the usefulness for you of the different types of cookies, they are presented below.
b. Cookies – Glossary
These cookies are solely served by BAYARD Group and are required for the proper functioning of the websites you use as well as to access the functionality of websites designed to ensure your browsing experience: browse as a subscriber on one of our press publications without having to log in each time, for example. They may also enable how our websites display to reflect your device preferences and the visualisation software installed on your device. The main cookies we use:
|Name of cookie||Function||Length|
|Device_view||adaptation of the website visited to the screen on your device||1 month|
|REMEMBERME||Stores your identify for future visits to the website||1 year|
|CART||Stores your basket at one of our stores…….||1 day|
Our websites employ analytical cookies designed to record the traffic, usage and performance of our websites, and to improve the functioning and user-friendliness thereof (for example, the most visited pages, visitor searches, etc…)
As the case may be, BAYARD Group uses the systems developed by AT INTERNET (xiti) and Google Analytics, which collect the information needed for the purposes of the aforementioned analysis.Sharing cookies (social media links)
To enable you to share articles and content with your friends and family or comment on them, our sites contain sharing links to the social media platforms (Facebook, Twitter). When you use these sharing buttons, a third-party cookie is installed. If you are logged on to the social network when you are browsing our website, the sharing buttons allow the content viewed to be linked to your user account.Advertising cookies
Our advertising department sells advertising space on our websites. Selling advertising space on our websites in particular allows BAYARD Group to pay for the free provision of quality services for users and subscribers on its websites. Without doing so, we could not, for example, offer you 5 free articles per month on www.la-croix.com
The adverts shown on our websites may contain:
- Cookies created by the advertiser (namely the party on whose behalf the advertising is shown) or by a third party connected with this advertising (audience measurement for example), and in particular make it possible to calculate the sums payable by the advertisers but also to limit the number of times you see an advert;
- Cookies created by our advertising department: These are cookies used to show you adverts tailored to your areas of interest on our websites. They are in particular used to limit the number of times you see an advert.
Moreover, certain cookies may be created by advertising intermediaries (Trading Desk, Google Adsens, SSP) and track you from one website to another to display advertising.
8. How can your rights to access, rectify, object, delete, portability and restriction of your personal data be exercised ?
Pursuant to the provisions of Articles 39 and 40 of the French Data Protection Act and European Regulation 2016/679, you can ask to be sent your Personal Data and require that, as applicable, your Personal Data be rectified, supplemented, updated, locked or deleted, where incorrect, incomplete, misleading, outdated, or where its collection, use, communication or retention is forbidden.
Pursuant to Article 18 of European Regulation 2016/679, you can also, where applicable, ask to restrict processing (for example, when you are challenging the accuracy of your Personal Data – while Bayard Group verifies the accuracy of your Personal Data, or when Bayard Group no longer needs your Personal Data for processing purposes but they are still needed by you to challenge, exercise or defend your legal rights).
Pursuant to Article 20 of European Regulation 2016/679, you can also, subject to the technical processes used by Bayard Group, request your Personal Data, in a structured, commonly-used and machine-readable format, to transmit it to another data controller for processing carried out by automated means to which you have given your consent.
For all these requests, simply contact the following address:Bayard Group
Data Protection Officer
18 rue Barbès
92128 Montrouge Cedex
Pursuant to French Decree 2007-451 of 25 March 2007 implementing the French Data Protection Act, your requests should be in writing, signed and accompanied by a photocopy of an identity document containing your signature. The request should indicate the address to which the response should be sent. Bayard Group has one month from receipt of your request in which to respond.
For your information, you may also contact the CNIL (French Data Protection Authority) (contact details can be found here https://www.cnil.fr/fr/vous-souhaitez-contacter-la-cnil) should Bayard Group not have followed up your request within one month. Where necessary, this period may be extended by two months, depending on the complexity and number of requests.