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1. Data Controller
1.1. The data controller is ETS CHARLES SCHMIDT, whose registered office is located at 15, passage de la Main d’Or, Paris, France (hereinafter referred to as “ETS Charles Schmidt”).
In this capacity, ETS Charles Schmidt – and/or its service providers acting on its behalf and for its account – determines the purposes and the technical and legal means of processing personal data and undertakes to take all necessary organisational measures to ensure that personal data is processed securely and in compliance with the applicable data protection legislation, including the General Data Protection Regulation of 27 April 2016 (hereinafter referred to as the “GDPR”).
1.2. ETS Charles Schmidt is free to appoint any natural or legal person to process users’ personal data on its behalf and for its account (hereinafter referred to as the “Data Processor”). Where applicable, ETS Charles Schmidt undertakes to select processors providing sufficient guarantees regarding the technical and organisational security measures implemented for the processing of personal data.
2. Processing of Personal Data
2.1. Use of the Website, access to certain sections and/or any requests for information or services submitted by Website users may involve the communication of personal data.
The processing of such data by ETS Charles Schmidt, acting as Data Controller, and/or by service providers acting on behalf of and for the account of ETS Charles Schmidt, shall comply with applicable data protection legislation and the GDPR.
2.2. This Privacy Policy is intended to inform users, before they access the various sections of the Website or provide their personal data, about how ETS Charles Schmidt processes their personal information.
Users are required to read this Privacy Policy before submitting their personal data through the forms provided in the various sections of the Website.
2.3. Personal data will primarily be processed by automated means, using procedures strictly related to the purposes set out in Section 3.
2.4. ETS Charles Schmidt also collects certain personal data from users in order to identify them, provide an optimal, high-quality and personalised browsing experience, and correct any errors that may occur on the Website.
The information collected relates to users’ connections (IP address, geographical area, date and time of visits, services accessed and/or used, etc.) as well as the devices used to access the Website.
2.5. In addition to the personal data directly provided by users (first name, surname, postal address, email address, etc.) when accessing the Website, the IT systems and software procedures responsible for the operation of the Website indirectly collect certain personal data, the transmission of which is inherent in the use of Internet communication protocols.
This data is processed solely for the purpose of carrying out anonymous statistical analyses.
2.6. Any failure to provide, or any partial or inaccurate provision of, personal data marked with an asterisk and therefore necessary to fulfil the requested service will make it impossible to provide that service.
However, failure to provide, or partial or inaccurate provision of, optional personal data that is not necessary will have no consequences.
3. Purposes of Personal Data Processing
3.1. Depending on the various sections of the Website, personal data may be processed for the following purposes:
a) To allow users to register on the Website, as registration may be required to access certain specific sections, as well as to use and interact with the various services offered;
b) Subject to the user’s prior consent and until such consent is withdrawn, to carry out marketing activities, including, but not limited to, sending promotional and advertising materials and conducting related analyses of registered users, enabling ETS Charles Schmidt to improve the services and products offered to its customers. This may include communications by email, MMS and SMS, subject to the user’s specific prior consent and until its withdrawal;
c) To manage the relationship between ETS Charles Schmidt and users, for example by sending newsletters containing information about Website updates, offers and menus;
d) To respond to users’ enquiries relating to ETS Charles Schmidt products or the Website itself (via the “Contact Us” section of the Website).
3.2. Registration on the Website is not required to access certain services offered by ETS Charles Schmidt, such as those mentioned in paragraphs c) and d) above.
However, in order to respond to users’ requests concerning these services, users may be asked to provide certain personal data, which will be processed solely for the purposes of handling the relevant request and only for the necessary period.
4. Cookies
The Website uses cookies to distinguish users from one another. This enables us to provide users with a good browsing experience and to improve the Website.
For detailed information about the cookies we use and the purposes for which they are used, please refer to our Cookie Policy.
5. Personal Data That May Be Processed
The following data may be collected and processed:
Information provided by users when completing forms or contacting us by telephone, email or any other means. This information may include users’ names, addresses, email addresses and telephone numbers.
For each visit to the Website, the following information is automatically collected:
- Technical information, including the IP (Internet Protocol) address used to connect to the Internet, browser type and version, time zone, browser plug-in types and versions, operating system and platform;
- Information about users’ visits, including URLs (Uniform Resource Locators), clickstream activity to and from the Website (including date and time), page response times, download errors, time spent on certain pages, browsing activity (such as scrolling, clicks and mouse movements), and methods used to navigate away from a page.
6. Consent
6.1. Users have the right to withdraw their consent at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
This right may be exercised by sending an email to:
7. Retention Period for Personal Data
In accordance with the legal requirements imposed by applicable data protection legislation and the GDPR, ETS Charles Schmidt retains users’ personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected and processed.
8. Disclosure of Users’ Personal Data for Internal Purposes
8.1. Personal data may be disclosed to employees or members of the Marketing Department of ETS Charles Schmidt who, acting under its direct authority, are appointed as persons responsible for processing or as data processors and receive appropriate operational instructions.
Personal data may also be made available to employees or collaborators of such processors where ETS Charles Schmidt has authorised this, provided that the data is processed in accordance with the intended purposes.
8.2. ETS Charles Schmidt ensures that its processors, employees and collaborators maintain the same level of protection as the company itself.
It also ensures that they process personal data solely for the authorised purposes, with the required confidentiality and security measures.
8.3. Personal data directly provided by users through online forms may be disclosed to and processed by the external service providers mentioned above, acting on behalf of and for the account of ETS Charles Schmidt.
9. Users’ Rights
9.1. ETS Charles Schmidt guarantees that users’ personal data will be processed fairly and lawfully.
9.2. Right of access
ETS Charles Schmidt guarantees users the right to access their personal data.
In accordance with Article 15 of the GDPR, users have the right to obtain the following information from ETS Charles Schmidt, including but not limited to:
a) The purposes of the processing;
b) The categories of personal data concerned;
c) The recipients or categories of recipients to whom the personal data has been or will be disclosed, particularly recipients located in third countries or international organisations;
d) Where possible, the envisaged retention period for the personal data or, where this is not possible, the criteria used to determine that period;
e) The existence of automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the GDPR and, at least in such cases, meaningful information about the logic involved, as well as the significance and expected consequences of such processing for the data subject.
9.3. Right to rectification and erasure
ETS Charles Schmidt guarantees users the right to have their personal data rectified or erased.
In accordance with Article 16 of the GDPR, incorrect or inaccurate data may be corrected or deleted at any time.
Users should first make the necessary changes themselves through their user account and may then request ETS Charles Schmidt to make such changes if they cannot be carried out independently.
Users also have the right to obtain the erasure of their personal data in the circumstances set out in Article 17 of the GDPR.
9.4. Right to restriction of processing
ETS Charles Schmidt guarantees users the right to restriction of processing.
Users have the right to obtain restriction of the processing of their personal data in the circumstances set out in Article 18 of the GDPR.
9.5. Right to data portability
ETS Charles Schmidt guarantees users the right to data portability.
In accordance with Article 20 of the GDPR, users have the right to receive their personal data in a structured, commonly used and machine-readable format.
They also have the right to transmit such data to another data controller without hindrance from ETS Charles Schmidt, where provided for under the GDPR.
9.6. Right to object to processing
ETS Charles Schmidt guarantees users the right to object to the processing of their personal data.
Users have the right to object at any time to the processing of their personal data where there are compelling and legitimate grounds relating to their particular situation.
ETS Charles Schmidt will then cease processing the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the user, or where processing is necessary for the establishment, exercise or defence of legal claims.
9.7. Right to lodge a complaint
ETS Charles Schmidt guarantees users the right to lodge a complaint regarding the processing of their personal data.
Users may lodge a complaint with the French Data Protection Authority (CNIL).
Website: https://www.cnil.fr/
9.8. Users may exercise any of the above rights at any time by sending an email to contact@schmidt-bronzier.fr or by post to:
ETS Charles Schmidt
15, passage de la Main d’Or
75011 Paris – France
10. Limitation of Liability of the Data Controller
The Website may contain hyperlinks to websites controlled and operated by third parties that are not affiliated with ETS Charles Schmidt.
Where applicable, ETS Charles Schmidt cannot be held responsible for the content of such websites or for the personal data protection practices of those third parties.
ETS Charles Schmidt cannot be held liable for data loss, data corruption or identity theft that may result, in particular but not exclusively, from the presence of viruses or cyberattacks.
The Website does not contain information specifically intended for minors.
Minors must not disclose personal information or data to ETS Charles Schmidt without their parents’ consent.
Accordingly, ETS Charles Schmidt encourages all persons exercising parental responsibility over minors to inform them about safe and responsible Internet use.
11. Procedures for Modifying a User’s Profile
Users may modify the information they have provided or delete their personal profile at any time by sending an email to the Data Controller at:
Alternatively, users may send a letter by post to:
ETS Charles Schmidt
15, passage de la Main d’Or
75011 Paris – France
12. Amendments to the Privacy Policy
ETS Charles Schmidt reserves the right to amend this Privacy Policy in order to comply with applicable data protection legislation or to adapt it to its own practices.
Users are therefore invited to consult this Privacy Policy regularly to stay informed of any changes or updates.