IDENTIFICATION :

Within the framework of its commercial activity of creator of online training, and its derived commercial activities, the NIWAKI ET CO Company is brought to treat information concerning you. For example, by browsing our websites, by filling out a newsletter subscription form, by clicking on an advertising link that we present to you, you send us information, some of which is likely to identify you ("personal data").

This Privacy Policy informs you of how we collect and process your personal data. We invite you to read it carefully.

Important: We only use your personal data in the cases provided for by the regulations in force:

        - The execution of a contract that we have concluded with you, and / or

        - Compliance with a legal obligation, and / or

        - Your consent to the use of your data, and / or

       - The existence of a legitimate interest in using your data. Legitimate interest is a set of commercial or business reasons which justifies the use of your data by NIWAKI ET CO SARL.

For any question relating to this document, you can contact the manager of the Company NIWAKI ET CO (dumasfrederique@yahoo.fr).

WHO IS RESPONSIBLE FOR THE PROCESSES MENTIONED IN THIS DOCUMENT?

The controller mentioned in this document is the company NIWAKI ET CO, a company with a capital of € 7,500, registered in the AUBENAS Trade and Companies Register, under number 514 027 614, whose head office is located at 600 Route de Balais - 07340 TALENCIEUX and of which Mrs Frédérique DUMAS, manager, is the legal representative.

WHAT DATA DO WE COLLECT FROM YOU AND IN WHAT CIRCUMSTANCES DO WE COLLECT IT ?


3.1 The data you send us directly

During the various contacts we have with you, you may be required to provide us with information that concerns you. They are collected in particular when subscribing to a newsletter, creating an account on our sites and applications or to access any other offer or any other service. These data include your e-mail address and any other information that you wish to bring to our attention.

3.2 The data we collect during our business relationship

- The data that we collect during our commercial relationship with you include the following:

        - Your participation in promotional offers, contests or events;

        - The requests that you have made to our after-sales service or the incidents that you have reported to us, for example concerning the performance of our services.

3.3 The data we collect automatically

During each of your visits to our sites and applications, we collect information relating to your connection and your navigation. Different technologies can be used to collect this data. The main one is the cookie.

Data collected through cookies

A cookie is a text file deposited during the consultation of a site, an application or an online advertisement and stored in a specific space of the hard drive of your computer or your mobile device. Cookies are managed by your Internet browser and only the issuer of a cookie can decide to read or modify the information contained therein. A cookie has a limited period of validity. Its deposit and storage on your terminal are done in compliance with the applicable legislation and subject to the choices you have expressed and which you can modify at any time.

A cookie does not identify you personally. It allows its transmitter to recognize your terminal and to collect a certain amount of information relating to the navigation carried out from this terminal.

Cookies have several functions, such as allowing you to navigate efficiently on a site or an application, remembering your choices, the goods and services you want to buy, offering you relevant advertising content according to your expressed interests, while browsing. You will find more information on cookies on the following sites:

www.cnil.fr

www.allaboutcookies.org

www.aboutcookies.org

www.youronlinechoices.eu

Data collected by standard Internet technologies

We are also likely to use standard Internet technologies, such as scripting, pixels, and redirects. Scripts (sometimes called tags), written in javascript, are programs that run in your browser and perform various actions, such as sending information to our servers. Scripts are also capable of creating pixels. Pixels (sometimes called transparent GIFs, clear GIFs or Web-bugs) are lines of code that allow you to display a graphic image (usually invisible) on a web page or in an email. Redirects allow you to make a web page available under multiple page addresses (URLs). When a browser opens a redirect URL, a page with a different URL is opened.

The purpose of these technologies is to improve your experience on our sites and applications, including to provide you with personalized content according to your interests. For example, when a user clicks an article sharing button, a script creates a pixel that accounts for the sharing. Thus, we are able to know the total number of shares of an article, and we can establish the ranking of the most shared articles. These technologies give us access to the following information in particular:

        - Information relating to your use of our sites and applications ;

        - Information relating to the presence of cookies on your terminal, on the time and date of consultation of a page, and a description of the page where the Web beacon is set ;

        - Information on the reading or not of the emails that we send to you, on the clicks that you make on the links contained in these emails.

Our sites may also include scripts, pixels, and third-party redirects. These technologies allow third-party service providers to collect certain information such as your browser type, and the web page that redirected you to our websites. These third-party service providers process the information they collect for the purpose of auditing, research, and to report information on our sites and applications and the advertisements viewed on them. We do not share your identification data with these third parties as part of their use of these technologies.

3.4 The data we assume

We may establish, by reconciling the data we have about you and general and anonymous statistical information, assumptions about the content and services able to meet your tastes or your uses.

Example: If, according to statistical data, a majority of people aged 30 to 50 years, living in Paris and interested in professional conversions 'Nature', are also passionate about niwaki and Japanese gardens, and you are one of our Parisian subscribers, 42 years old who regularly consult on our site articles related to the creation of Japanese gardens, we will assume that you are also interested in the relevant training and we will be able to show you during navigation on our site advertising for such training.

3.5 Data relating to minors

In principle, our products and services are aimed at adults who are able to sign contractual obligations.

The minor user must obtain the consent of their legal guardian prior to the communication of personal data concerning them. For registration on our sites and some of our online services (newsletter for example), the age of 16 is accepted.

An internet user under the age of 18 at the time of publication or creation of an online account has a specific right to erase data concerning them. For any information, please contact the responsible person (dumasfrederique@yahoo.fr)

3.6 Data relating to a third party

Before offering a subscription or any other product or service that we market to a third party, you must ensure that the person concerned accepts that his personal data, in particular his postal address, be communicated to us.

3.7 Exclusion of any sensitive data

SARL NIWAKI ET CO does not collect any sensitive data concerning you.

The following are considered sensitive data: racial or ethnic origin, political opinions, religious or philosophical beliefs, membership of a union, data relating to health or sexual orientation. If such information is in any way communicated to us, it will be deleted.

FOR WHAT PURPOSES DO WE USE YOUR DATA ?

This article tells you the main purposes for which we use the data mentioned in article 3.

4.1 Operations necessary for the supply of products or services

        - Management of subscriptions to our newsletters and / or email alerts ;

        - Customer relations : provision of an e-mail address for any question or complaint ;

        - Conducting surveys (satisfaction, market research ...);

        - Sending information on the modification or evolution of our services ;

        - Management of the exercise of your rights over your personal data, under the conditions provided for in article 9 ;

        - Verification of compliance with applicable legislation, our contracts and general conditions of use.

4.2 Marketing and commercial prospecting operations relating to the publications, products and services of SARL NIWAKI ET CO

        - Updating postal standards, updating, enriching your personal information in a dedicated database ;

        - Sending information on the company, its publications and its activity ;

        - Sending marketing, advertising and promotional offers relating to our products and services by postal mail, e-mailing campaigns, mobile notifications, on social networks or any other medium ;

        - Custom loyalty or prospecting actions ;

        - Implementation of contests or other promotional operations ;

        - Collection of customer reviews ;

        - Development of trade statistics.

4.3 Operations linked to commercial partnerships

SARL NIWAKI et Co does not share with, exchange with, or rent files from business partners.

4.4 Purposes associated with the deposit of cookies on your browser

        - Operation and optimization of navigation on our sites and applications ;

        - Adaptation of the presentation of our sites and applications to the display preferences of your terminal (language used, display resolution, operating system, etc.) during your visits, depending on the hardware and software for viewing or reading that your terminal contains ;

        - Memorization of information relating to a form that you have completed on our site (registration or access to your account) or to products, services or information that you have chosen on our site (subscribed service, content viewed, purchase made, etc.) ;

        - Automatic connection to the reserved or personal areas of our site, such as your account, using identifiers or data that you have previously entrusted to us ;

        - Provision of sharing tools on social networks ;

        - Management of our platforms and realization of internal technical operations within the framework of problem solving, data analysis, tests, research, analyzes, studies and surveys ;

        - Implementation of security measures ;

        - Quality measures to ensure that the display of our content is suitable for your device ;

        - Measurement of attendance and audience ;

        - Establishment of statistics and volumes of attendance and use of the various elements making up our site (sections and content visited, routes) in order to improve the interest and ergonomics of our services ;

        - Accounting for the total number of advertisements displayed by us on our advertising spaces, ranking and statistics ;

        - Analysis of audiences based on the results of advertising campaigns ;

        - Determination of interests and behaviors ;

        - Improvement of customer / user knowledge for personalization purposes ;

        - Personalization of the advertisements present on our sites and applications ;

        - Adapt advertising spaces to the display preferences of your terminal (identification of advertisements, compilation of statistics and volumes of attendance and use of the various elements making up our site: sections and content visited, routes) in order to improve interest and the ergonomics of our services ;

        - Adapt the advertisements displayed on your terminal when you browse our sites and applications to its technical characteristics (1), to your previous browsing choices (2), to your interests and uses (3), to the data that you previously communicated to us (4), if applicable, to the geographic location data of your terminal (5) ;

        - Recognize you for displaying personalized advertisements on social networks ;

       - Measure the effectiveness of our advertising campaigns and service proposals.

FOR HOW LONG DO WE KEEP YOUR DATA ? 

Your personal data is kept for a period in accordance with legal provisions or proportional to the purposes for which it was recorded. Certain retention periods meet the legitimate interest of SARL NIWAKI ET CO as specified in the introduction.

The retention periods vary depending on whether we have an ongoing contractual relationship (you are an active customer), whether we have had a contractual relationship with you in the past (you are an inactive customer) or whether we have never had such a relationship with you (then you are a prospect).

The data linked to your browsing on our online services collected by cookies that you have authorized have a specific retention period.

WHO IS LIKELY TO HAVE ACCESS TO THE DATA WE COLLECT ?

6-1 Access to data within SARL NIWAKI ET CO

Are likely to have access to some of your data :

Employees from the administrative, accounting and management control, IT, and marketing & sales departments.

Access to your data is made on the basis of individual and limited access authorizations. The personnel who can access personal data are subject to an obligation of confidentiality (by a nominal commitment and personal confidentiality).

6-2 Data transmission

The subcontractors

They provide services on our behalf, including :

        - Management of telephone calls, sending of postal or digital mails ;

        - Personalization of the content of sites and mobile applications ;

        - Carrying out maintenance operations and technical developments ;

        - Collection of customer reviews ;

        - Provision of analytical solutions or audience measurement statistics.

The access of our subcontractors to your data is made on the basis of signed contracts stating their obligations with regard to the protection of data security and confidentiality.

Social media platforms

The use of social networks to interact with our sites and applications (in particular the "share" buttons on Facebook, Twitter, Google+) is in fact likely to lead to data exchanges between SARL NIWAKI ET CO and these social networks. For example, if you are connected to the Facebook social network and you consult a page of the site www.frederique-dumas.com, Facebook may collect this information. Similarly, if you consult an article on the site www.frederique-dumas.com and click on the "tweet" button, Twitter will collect this information.

We therefore invite you to consult the personal data management policies of the various social networks to be aware of the collections and processing they carry out on your data.

Police, judicial or administrative authorities

When we have the legal obligation to do so or to guarantee the rights, property and safety of SARL NIWAKI ET CO.

IS YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

 We store your personal data in the European Union. In all cases, we ensure that the processing is carried out in accordance with this confidentiality policy and that it is framed by the standard contractual clauses of the European Commission which make it possible to guarantee an adequate level of protection of privacy. and fundamental human rights.

HOW IS YOUR DATA PROTECTED ?

As data controller, we implement appropriate technical and organizational measures in accordance with applicable legal provisions, to protect your personal data against alteration, accidental or unlawful loss, use, disclosure or unauthorized access. authorized, and in particular :

        - The appointment of a data protection officer ;

        - The creation of a unit dedicated to the security of information systems ;

        - Awareness of the confidentiality requirements of our employees who need to access your personal data ;

        - Securing access to our premises and our IT platforms ;

        - The implementation of a general IT security policy for the company ;

        - Securing access, sharing and transfer of data ;

        - The high level of data protection requirements when selecting our subcontractors and partners.

WHAT ARE YOUR RIGHTS ?

9.1 Your rights regarding access to your personal data

You have the right to access your personal data and to request that it be rectified, supplemented or updated. You can also request the erasure of your data or oppose their processing, provided that you justify a legitimate reason.

You can request to exercise your right to the portability of your data, i.e. the right to receive the personal data that you have provided to us in a structured, commonly used format and the right to transmit this data to another data controller.

Finally, you can formulate directives relating to the storage, erasure and communication of your personal data after your death.

You can exercise your rights with the person responsible for the protection of personal data of SARL NIWAKI ET CO - 600 Route de Balais - 07340 TALENCIEUX or by email: dumasfrederique @ yahoo.fr.

Before responding to your request, we may verify your identity and / or ask you to provide us with more information to respond to your request. We will endeavor to comply with your request within a reasonable time and, in any event, within the time limits set by law.

In the event of an unsatisfactory response, you can lodge a complaint with the National Commission for Data Protection (CNIL).

9.2 Your rights in opposition to commercial solicitations

We may use your contact details for commercial solicitations, in accordance with applicable law and the clauses of this privacy policy. You can object to these requests at any time, according to terms which depend on the communication channel we use to send them to you.

Commercial solicitations by electronic means (e-mail) :

We respect the rules of article L.34-5 of the post and electronic communications code which provides for the prior and express collection of your consent for the sending of commercial prospecting by electronic means (e-mail, push notifications or SMS).

However, your express and prior consent is not compulsory when you are already a client of SARL NIWAKI ET CO and the object of our request is to offer you products or services similar to those that we already provide to you.

In any case, you always have the possibility of opposing the reception of these requests by clicking on the unsubscribe link provided in each e-mail.

9.3 Your rights regarding acceptance and management of cookies

Saving a cookie on your navigation device is subject to your will. You can change your choices regarding the acceptance or refusal of cookies placed on your terminal at any time, either on your browser or online with different operators. In order to manage cookies as closely as possible to your wishes, we invite you to configure your browser taking into account the purpose of the cookies.

How to exercise your choices ?

1. Make your choices on your browser

You can configure your browser software either so that the acceptance or refusal of cookies is promptly offered to you, before a cookie is likely to be saved, or to systematically accept or refuse the recording of cookies in your terminal. We alert you to the fact that any configuration on your navigation software concerning the refusal of technical and functional cookies will be likely to affect your browsing comfort on our websites, or even prevent the use of some of our services requiring the use of these same cookies. If necessary, we decline all responsibility for the consequences linked to the degraded functioning of our websites and our services resulting from the impossibility for us to save or consult the cookies necessary for their functioning and that you would have refused or deleted. For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to modify your preferences regarding cookies.

2. Make your choices online

Analytical cookies allow us to obtain anonymous statistics of visits to our site in order to optimize it and detect possible malfunctions. They are posted on our sites and applications by the companies Google Analytics, ATInternet (XiTi), Parse.ly, Weborama, ACPM.

For social media cookies, we use the Facebook, Twitter, Pinterest, Google+ and LinkedIn share buttons. Disabling these cookies therefore prevents any interaction with social networks.