Caviar Multimédia

The following words and expressions, when they appear with a capital letter in the Policy, have the meaning attributed to them below, unless otherwise implied or explicitly stated in the text:

• “Fournisseur de services” : Toute personne physique ou morale qui traite les données pour le compte de Caviar Multimédia. Il s’agit de sociétés tierces ou de personnes employées par Caviar Multimédia pour faciliter les Services, fournir les Services pour le compte de Caviar Multimédia, effectuer des services liés aux Services ou aider Caviar Multimédia à analyser l’utilisation des Services.
• “Personal information”: Any information that relates to a natural person and allows them to be identified, i.e. that reveals directly or indirectly something about the identity, characteristics (e.g., skills, preferences, psychological tendencies, predispositions, mental capacities, character and behavior of the person concerned) or activities of that person, regardless of the nature of the medium and regardless of the form in which this information is accessible (written, graphic, audio, visual, computerized or other).
• “Sensitive Personal Information”: Means Personal Information which, by its nature or because of the context in which it is used or disclosed, gives rise to a high degree of reasonable expectation of privacy. This may include, for example, medical, biometric, genetic or financial information, or information about sexual life or orientation, religious or philosophical beliefs, trade union membership or ethnic origin.
• “Privacy Officer”: The person who is responsible for the application of this Policy and whose contact details are identified in section 1.2 of this Policy.
• “Services”: Services refers to the Website and all related services offered by Caviar Multimedia, which include professional services and, where applicable, associated media, printed materials and “online” or electronic documentation.

3.1 Collection of Personal Information

Your consent to share your personal information with us is crucial. Caviar Multimedia takes your privacy and data confidentiality very seriously. That's why we've developed this privacy policy to tell you what information we collect, how we process it, and when we need to share it with subcontractors or third parties.

By giving your consent, you authorize Caviar Multimedia to collect and process your personal information as necessary to provide you with our services. Please be aware that you remain in control of your personal information at all times and that the consent you give us at the time of collection or processing of your personal information can be withdrawn at any time. We will ensure that we respect your choice in accordance with our legal obligations.

Furthermore, it is essential to read this Policy.

In the course of our business, we may collect, process and use different types of Personal Information that you provide to us only if the law allows us to do so, including the information listed below:

Via our Website:

• Contact information, such as your first and last name, address, email address and company name to subscribe to our newsletter or to create a user account if required with us;

Information automatically collected by Google for Analytics reports when using the Website and our Services, including:

• Log information and other information about your activities on the Website, such as your IP address, the pages you visit, the time and date of your visits, the type of browser you use, your device's operating system and other hardware and software information that is captured;

• Geolocation data, such as your IP address, precise or approximate location determined from your IP address or your mobile device's GPS (depending on your device settings);

Information regarding your credit card or other payment method, as well as other related information for any transactional section that may appear on our Website.

• Personal Information may also be collected by our online payment partners. You may submit a request to the controller as indicated in section 1.2 to learn more about their methods of processing, storing, and destroying your Personal Information. We invite you to consult their privacy policy.

In carrying out mandates that you entrust to us and when this could apply:

• Contact details such as your first and last name, email address, telephone number, address and company number for the creation of a customer account;

• Information relating to products or services, such as information concerning the services we have provided to you;

• Transaction and payment information such as the payment method used, date and time, payment amount, billing postal code, your address and other related information;

• Information you choose to provide or share with us, for example, when you fill out a form, respond to surveys or communicate with one of our employees or representatives.

In each case, this personal information is processed in accordance with the legitimate and necessary purposes listed in Article 3.2 below. In addition, we ensure that we collect and process only the data and Personal Information that is strictly necessary for the purposes for which you provide it to us. If any subsequent use of your Personal Information should take place, we will notify you as required by law.

3.2 Use of Personal Information

In accordance with the statement in paragraph 3.1, we only use your Personal Information if the law allows us to do so. We may use your Personal Information for the legitimate purposes described below:

• provide Services;

• allow you to subscribe to our newsletter;

• verify your identity and review your personal background, as permitted by law;

• operate, maintain, supervise, develop, improve and provide all features of our Website;

• manage risk and activities;

• comply with our obligations under applicable laws and regulations;

• develop new Services and improve our Website and Services;

• for marketing and business development purposes, if you have previously consented to the processing of your personal information for these purposes;

• send messages, updates, security alerts;

• answer your questions and provide assistance as needed;

• administer a contest, promotion, survey or other feature of the Website or our Services;

• collect opinions and comments regarding our Services;

• conduct research and analysis related to our business and Services;

• detect and prevent fraud, errors, spam, abuse, security incidents and other harmful activities;

• establish, exercise or defend a right or legal procedure;

• transmit communications in accordance with the law;

• enable the function to apply for a job with Liberté Numérique;

• any other purpose permitted or required by law.

Please note that we do not use the information we collect to draw inferences or make any interpretations.

The Personal Information we collect and store remains encrypted and securely stored on Hostinger's servers in South Carolina, USA. Please be assured that this Personal Information is only disclosed when we have a legal obligation to do so.

3.3 Communication of Personal Information

We may share your Personal Information with our employees, contractors, consultants, agents, Service Providers and other trusted third parties who require such information to help us operate our Website and conduct and protect our business activities.

In addition, only members of our organization's staff who have a need to access and process your Personal Information will have access to it, in accordance with our internal Personal Information Protection Policy.

We do not sell, trade, or otherwise share your Personal Information with third parties, except as otherwise permitted by law.

3.3.1 Service Providers and Other Third Parties

Although we try to avoid sharing your Personal Information with third parties, we may use Service Providers to perform various services on our behalf, such as IT management and security, marketing, as well as data analysis, hosting and storage. We have defined below the cases in which such sharing may take place:

• We use MailChimp to collect information related to our newsletter. See their privacy policy by clicking: https://www.intuit.com/privacy/statement/

In the context of these contracts concluded with our Service Providers, we undertake to ensure that the principles set out in this Policy are respected, and these Service Providers are required to use Personal Information according to our instructions and only for the purposes for which it was provided.

In addition, these Service Providers provide us with sufficient guarantees regarding the implementation of adequate safeguards that are proportionate to the sensitivity of the Personal Information processed or disclosed. When our Service Providers no longer need your Personal Information, we require them to destroy this data appropriately.

3.3.2 Compliance with legislation, responding to legal requests, preventing harm and protecting our rights

We may disclose your Personal Information when we believe such disclosure is permitted, necessary or appropriate, including:

• respond to requests from public and government authorities, including public and government authorities outside your country of residence;

• protect our activities;

• comply with legal proceedings;

• protect our rights, privacy, safety, property, yours or those of others;

• to enable us to exercise available remedies or limit the damages that we may suffer; and

• in accordance with applicable laws, including laws outside your country of residence.

3.3.3 Commercial transaction

We may share, transfer or disclose, where applicable and in strict accordance with this Policy, your Personal Information in the event of a sale, transfer or assignment, in whole or in part, of Caviar Multimédia or our assets (for example, as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation or any other business transaction, including in connection with the negotiation of such transactions). In such event, we will notify you before your Personal Information is transferred and becomes governed by a different privacy policy.

3.3.4 Consent to Personal Information

Where possible, Caviar Multimedia obtains consent directly from the individual concerned to allow us to collect, use and disclose their Personal Information. However, if you provide us with Personal Information about other individuals, you must ensure that you have duly notified them that you are providing us with their information and have obtained their consent to such disclosure. Under no circumstances can we be held responsible for this information.

We will seek your explicit consent before using or disclosing your Personal Information for purposes other than those stated herein.

3.3.5 Retention of Personal Information

Subject to applicable laws, we retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, unless you consent to the use or processing of your Personal Information for another purpose.

Additionally, our retention periods may be modified from time to time due to legitimate interests (for example, to ensure the security of Personal Information, to prevent abuse and violations or to prosecute criminals).

Please also be assured that when the purpose for which information was collected is fulfilled, we proceed to destroy or anonymize this information, in accordance with applicable legislation.

For more information on the periods for which your Personal Information is retained, please contact our Privacy Officer using the contact details provided in section 1.2 of this Policy.

As a data subject, you can exercise the rights set out below by writing and sending by email or by post to the attention of our Privacy Officer at the contact details provided in article 1.2 of the Policy:

• You have the right to be informed of the Personal Information we hold about you and to request a paper copy of the documents containing your Personal Information, subject to the exceptions provided by applicable law;

• You have the right to have the Personal Information we hold about you rectified, amended and updated if it is incomplete, ambiguous, out of date or inaccurate;

• You have the right to withdraw or modify your consent to Caviar Multimédia collecting, using, communicating or retaining your Personal Information at any time, subject to applicable legal and contractual restrictions;

• You have the right to ask us to stop disseminating your Personal Information and to de-index any link attached to your name which gives access to this information if this dissemination contravenes the law or a court order;

• You have the right to file a complaint with the Commission for Access to Information, subject to the conditions provided for by applicable law.

In order to process your request, you may be asked to provide appropriate identification or otherwise identify yourself.

We encourage all our clients to keep their personal information up to date. Decisions regarding the various services we offer to our clients may vary depending on the accuracy of this information. It is therefore essential to ensure we have an accurate picture of your situation.

Caviar Multimedia has implemented technological and organizational security measures to adequately protect the confidentiality and security of your Personal Information against loss, theft, or unauthorized access, disclosure, reproduction, communication, use, or modification. These measures include, in particular, encryption and access control.

Among the various measures put in place:

• Our Website uses Secure Sockets Layer (SSL), firewalls, network monitoring software and computer backup to ensure a secure connection between your device and our server;

• Caviar Multimedia employees have read this Policy and have undertaken to comply with it and to respect the confidentiality of Personal Information concerning our potential and existing customers. In addition, each employee undertakes to follow and respect a data governance policy applicable to all Caviar Multimedia staff;

• As mentioned in section 3.3, we have implemented Personal Information access measures that limit access only to those persons who have a valid reason to consult, process, communicate or otherwise use your information;

• As mentioned in section 3.3, subcontractors and third parties who do business with Caviar Multimédia and with whom we sometimes have to communicate your Personal Information have previously undertaken to protect the confidentiality and privacy of this information;

• When the purpose for which your Personal Information was collected is satisfied and we no longer need to retain it, Caviar Multimédia proceeds to destroy or anonymize this data, subject to applicable laws.

Despite the measures described above, we cannot guarantee the absolute security of your Personal Information. If you have reason to believe that your Personal Information is no longer protected, please contact our Privacy Officer immediately using the contact details provided in Section 1.2 above.

We reserve the right to modify this Policy at any time in accordance with applicable law. You can consult our Privacy Policy page at any time. We adjust the update date in Section 9 of this Policy.

If you do not agree to the new terms of the Privacy Policy, we encourage you to stop using our Website and Services. If you choose to continue using our Website or Services after the new version of our Policy becomes effective, your use of our Website and Services will be governed by the new version of the Policy.

From time to time, we may include on our Website references or links to websites, products, or services provided by third parties (the “Third Party Services”). These Third Party Services, which are not operated or controlled by Caviar Multimedia, are governed by privacy policies that are entirely separate and independent from ours. We therefore assume no responsibility for the content and activities of these sites. This Policy applies only to the Website and the services we offer. This Policy does not extend to Third Party Services.

Caviar Multimedia undertakes to take all reasonable means to ensure a level of confidentiality and security of Personal Information in accordance with appropriate technological standards given its sector of activity.

Notwithstanding the foregoing, you declare that you understand and acknowledge that no computer system offers absolute security and that a degree of risk is always present when transmitting Personal Information over the public network that is the Internet.

You agree that Caviar Multimedia cannot be held liable for any breach of confidentiality, hacking, virus, loss, theft, misuse or alteration of Personal Information transmitted or hosted on its systems or those of a third party. You also declare that you waive any claim in this regard, except in the event of gross negligence or willful misconduct on the part of Liberté Numérique.

Accordingly, you agree to release Caviar Multimedia and its officers, directors, affiliated persons and business partners from any liability for any damages of any kind, whether direct or indirect, incidental, special or consequential, in connection with the use of your Personal Information.

In the event of a breach of the confidentiality or security of your Personal Information that presents a high risk to your rights and freedom, this breach will be notified to you as soon as possible, and Caviar Multimédia will take the necessary measures to preserve the confidentiality and security of your Personal Information.