DEFINITIONS

Capitalised terms have the following meanings:

"The Company" or "we" means Muzisecur, with its registered office at 11 rue des Jacinthes, 29720 Ploneour-Lanvern, registered with the Trade and Companies Register under number 890 493 885, represented by its President Mr. Tarik HAMICHE.
"The Website" means the website(s) accessible at http://www.muzisecur.fr and any sub-sites providing access to content, a customer area, etc., operated by the Company.
"You" means the data subjects affected by the processing carried out on the Website (users, prospects, customers, etc.).
"The Policy" means this privacy policy.
"Data" means any information relating to an identified or identifiable natural person (the "data subject"), directly or indirectly, in particular by reference to an identifier (name, identification number, location data, online identifier, etc.) or to one or more factors specific to their identity.
"Processing" means any operation performed on Data (collection, recording, organisation, storage, adaptation, communication by transmission, dissemination, erasure, etc.).
"Data controller" means the entity that, alone or jointly with others, determines the purposes and means of processing; a "processor" is the entity that processes Data on behalf of the controller. On the Website, unless otherwise stated, we are the data controller.
"Recipient" means any natural or legal person, public authority, service, or any other body that receives communication of personal data, whether or not a third party.
"Regulations" means Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (the "GDPR"); French Law No. 78-17 of January 6, 1978, on Information Technology, Data Files, and Civil Liberties; the rules on commercial prospecting under the French Postal and Electronic Communications Code; and more generally, all laws and regulations applicable to the processing of Data that we carry out.

SHOWCASE WEBSITE

The Website presents our Company's activities and various forms (contact, newsletter subscription, etc.). By completing forms and communicating with us via the Website, you provide us with the following categories of information:

Identity data: title/gender; surname; first name; and optionally, your date of birth for birthday offers;
Contact and correspondence data: email address; postal address (street, postcode, city); phone number; nature and content of any customer service request.
Reviews and contributions data: username, review date, review content, product or service concerned, and any associated profile picture;
Data required for loyalty, prospecting, survey, product testing, and promotional activities.
Data relating to the organisation and processing of competitions, prize draws, and any promotional operations;
Data collected through exercising the rights granted by the Regulations.

In accordance with our legitimate interest, and where necessary for the performance of pre-contractual measures taken at your request or for the performance of a contract, we process the above Data for the following purposes:

Presentation of the Company's products and services;
Management, processing, and follow-up of requests and exchanges with the Company via the Website (including chatbots, call booking tools, etc.);
Management of relationships with prospects;
Management of reviews on the Company's products, services, or content;
Prospecting and/or sending information; managing technical prospecting operations; selecting individuals for loyalty, prospecting, survey, and product testing activities;
Organisation of competitions, prize draws, or any promotional operations on the Website.

In compliance with our legal obligations, identity and contact data will also be processed for the following purposes:

Updating prospecting files by the body managing the telephone canvassing opt-out list, in accordance with the French Consumer Code.
Handling requests for access, rectification, and objection, and more generally the rights described in this Policy.

COOKIES

On the Website, we use several types of cookies including those necessary for the Website to function, for performance, content exchange, and cookies and trackers for marketing and advertising targeting purposes. Cookies are retained for a maximum of 13 months after they are first placed on your device, and this period is not extended upon subsequent visits.

Cookies allow us to collect Website browsing data (IP address, Internet service provider, hardware and software configuration, browser type and language).

Cookies may be used:

for statistical purposes and to improve the Website, optimising the services provided by processing information about access frequency, page personalisation, and operations performed on the Website;
to facilitate and improve your experience by allowing us to record your actions on the Website and your preferences;
for advertising purposes, in particular to offer you targeted content. Certain Website features such as video players or interactive content may use third-party services that deposit cookies enabling them to identify your content viewing.

If you do not wish cookies to be used on your device, most browsers allow you to disable cookies through their settings. However, please note that certain services may no longer function correctly.

ONLINE SALES

The Website allows purchases, which requires us to process the following Data:

Identity and contact data
Contractual and commercial relationship data: order details; pre-contractual and order-related exchanges (subject, date, etc.); communications with the Company.
Payment and transaction data: transaction date, amount, payment method, order number, billing data.

This information is necessary for managing our customer-prospect file, specifically for the following purposes in accordance with our Terms and Conditions accepted at the time of ordering and our legal obligations:

Operations relating to the management of files concerning: contracts including registrations; orders; product or service delivery; legal and commercial warranties; invoices; accounting; and monitoring the commercial relationship (after-sales service), including reviews of the Company's offerings;
Prevention and combating fraud, particularly payment card fraud; management of unpaid debts and litigation, provided this does not relate to offences and/or does not result in the exclusion of the individual from a right, benefit, or contract.

In accordance with Article L.612-1 of the French Consumer Code, in the event of a dispute, you may contact the following consumer mediator: MCP Mediation, 12 square Desnouettes, 75015 Paris, France, by post or via http://mcpmediation.org

Secure payment. All transactions on our Website are secure. Credit card payments are handled by our payment service providers ("PSPs"), as indicated in our terms and conditions or on the product and service order page. We use SSL encryption to protect your personal data and payment methods. At no point do we directly hold your bank details through this process.

ACCOUNT CREATION

Creating an account is optional for placing an order on the Website. If you create an account, the following information will be processed:

Identity and contact data
Account login data: username, password; these may be automatically saved on the Website only if you consent via your browser settings;
Account access and usage data: IP address, connection time, connection duration, account settings, use of any account features.

Processing will be carried out for managing authentication procedures, lost username or password procedures, and as needed for order fulfilment in accordance with the purposes set out for online sales.

With your consent, the identity and contact data provided during account creation will be used to inform you about the Company's products and services.

The Company may provide tools for creating a profile by adding optional information to your account (identity, social media, age, profile picture, profession, etc.).

DELIVERY OF PHYSICAL PRODUCTS

To deliver products ordered on the Website, we will ask for your delivery address if it differs from the billing address. If the delivery is intended for a third party, you confirm that you have authorisation to provide their identity and delivery information. This Data will be shared with the carrier responsible for delivery.

Other information necessary for delivery will be processed in accordance with our Terms and Conditions and our legitimate interest (delivery method, parcel size, tracking information, delivery date, proof of receipt, signature, etc.).

The carrier responsible for delivery applies its own privacy policy to the Data transmitted in connection with the order or collected during delivery.

PROVISION OF DIGITAL CONTENT

The legal basis for processing related to the provision of digital content is contractual, and where not covered by the Terms and Conditions, is based on our legitimate interest. For this purpose, we will process the following Data:

Identity and contact data
Content access data: username and password (which may be automatically saved only with your browser consent), and login information (IP address, connection time, duration, use of any available tools).
Content-related data: content viewing data and tracking: module viewing data, time spent on content; information about audio files downloaded and/or listened to.
Progress data: progress indicators, statistics and progress tracking; any notes, surveys and quizzes completed, assessments taken.
Publication data: content of your contributions (comments, questions, posts, reviews, etc.), date, time, response rate, information about the relevant publication space.

The Website from which content is accessible may include technical devices that track Website usage (logged-in user account, IP address, application type, various connection and usage logs, etc.). Data from these devices may be used for anti-counterfeiting purposes and/or to identify and/or prevent any unlawful or non-compliant use of the Website and/or breach of the applicable Terms and Conditions.

PERSONALISED SUPPORT SERVICES

The legal basis for processing related to personalised support services is contractual, and where not covered by the Terms and Conditions, is based on our legitimate interest.

We offer personalised support services for which we will collect and process the following Data:

Organisational data: identity, contact details, information about booked, cancelled, and completed appointments, and all information necessary for organising this type of service;
Progress data: progress indicators, any notes taken during the support, data from audits, surveys and quizzes completed, assessments taken, information necessary for producing a summary report.

EVENTS

Registration and organisation. We may organise in-person or remote events, conferences, social or business events ("Events") that may be free or paid. Personal data necessary for the organisation, management, processing, and follow-up of invitations, registrations, and attendance at these Events are subject to automated data processing.

Image rights. We may capture your image and/or voice on photo, audio, or video media during an Event, in accordance with our Terms and Conditions or any separate agreement. Recordings may be stored and published by the Company, including on social media, in accordance with its legitimate interests. If you do not wish to appear, you may turn off your camera for remote events, stand at the back of the room, avoid group photos, or signal to the photographer/videographer during in-person events.

SOCIAL MEDIA AND THIRD-PARTY WEBSITES

Social media exchanges. We may contact you or respond to your questions via social media if you initially contacted us through that channel. Please be aware that the use of social media involves data processing by those social media providers (see their respective privacy policies).

Public information. Information about you that you have provided to us may be supplemented for commercial, prospecting, communication, solicitation, or marketing purposes using other information sources such as social media. This includes information deemed "public" or to which we have access as administrator of a page or group. The legal basis for this processing is our legitimate interest as a commercial company.

Interconnection. Where your member area can connect to another service (e.g. a social network) for cross-posting, the third-party service may share information that you have authorised for disclosure. Please note that third-party service providers may also collect information about your browsing and/or use of the Website, in accordance with their own data processing policies.

EXERCISING YOUR RIGHTS

General. You have the right to access, rectify, or erase your data, to request information, to restrict processing, to data portability, and to withdraw consent, within the limits set by the applicable regulations, in particular the GDPR where applicable. Following the exercise of the right to erasure, objection, or withdrawal of consent, the proper functioning of the Website and/or service may be disrupted or interrupted.

Right to object. You also have the right to object at any time, on grounds relating to your particular situation, to processing of your personal data based on our legitimate interest. Regarding commercial prospecting (newsletters, etc.), you may unsubscribe at any time from the mailing list by clicking the unsubscribe link or by contacting us.

How to exercise your rights. You may contact us for more information and to exercise your rights. Requests should be sent by email to contact@muzisecur.fr or by post to the Company's registered office address shown above. We reserve the right to request proof of identity and to ask you to clarify your request. If you are not satisfied with our response, you may file a complaint with the relevant data protection authority (in France, the CNIL).

Retention period. When exercising the right of access or rectification, identity documents may be retained for the period provided for in Article 9 of the French Code of Criminal Procedure (one year). When exercising the right to object, such data may be archived for the limitation period provided for in Article 8 of the French Code of Criminal Procedure (three years).

DATA RETENTION PERIODS

Commitments. Effective data deletion measures are implemented once the retention or archiving period necessary for the specified or legally required purposes has been reached, including after the deletion of your account with our Company or upon termination of the contract.

Minimisation. In all cases, Data subject to processing is not retained beyond the time necessary to fulfil the obligations defined at the time the contract was entered into, or imposed by applicable legislation. Beyond this, Data may be anonymised and retained for statistical purposes, in particular in aggregate form.

Commercial prospecting. Data used for commercial prospecting purposes is retained for a maximum of three years from the last active contact from the prospect or customer, or earlier if you withdraw your consent to receive messages from us.

Electronic contracts. Under our legal obligations, certain internal documents containing personal information (purchase orders, contracts, invoices, etc.) will be archived. In particular, any contract concluded electronically for an amount equal to or greater than EUR 120 will be archived for 10 years from the conclusion of the contract if the goods are delivered or the service is performed immediately, or from the delivery or performance date.

Litigation. We may also archive information demonstrating the performance of our contractual obligations until the expiry of applicable limitation periods, for the proper defence of our interests before the courts in the event of subsequent litigation. This includes, but is not limited to, the periods provided for by the French Commercial Code, the Civil Code, and the Consumer Code.

RECIPIENTS

Commitments. We are committed to ensuring that any data recipient provides sufficient and appropriate contractual guarantees to respect your rights, so that processing meets the requirements of the GDPR where applicable (particularly regarding sub-processing). On the basis of our legal obligations, your Data may be disclosed pursuant to a law, regulation, or decision of a competent regulatory or judicial authority.

The information you provide is for internal use by authorised personnel only, is strictly confidential, and may not be disclosed to third parties except as provided by the Regulations, with your express consent, or if you have chosen to make it public.

Sub-processing. Our external service providers (e.g. suppliers, carriers, etc.) may, in the context of the processing described above, receive personal data where necessary for the performance of their duties.

Commercial partnerships. For commercial prospecting purposes, we will seek your consent before sharing your information with commercial partners. We also reserve the right to make joint offers with third parties, of which you will be notified. If you order a product or service on the Website that is not delivered directly by the Company but by a commercial partner, we will share the information necessary to fulfil the order with that partner.

Transfers outside the EU. We are committed to complying with applicable regulations regarding data transfers to countries outside the European Union, in particular by:

Transferring data of visitors, prospects, and customers to countries recognised as providing an adequate level of protection;
Where the destination country does not provide an adequate level of protection, we frame transfers using compliant transfer mechanisms (in particular, the European Commission's standard contractual clauses).

Aggregation of non-personal data. We may publish, disclose, and use aggregated information (relating to Website users, prospects, customers, etc.) combined in such a way that no individual can be identified. This processing is carried out in accordance with our legitimate interest for statistical purposes, industry and market analysis, presentation of our activities, and for promotional, advertising, and other commercial purposes.

IT SECURITY

Commitments. We are committed to implementing all appropriate technical and organisational measures through physical and logistical security to ensure a level of security appropriate to the risks of accidental, unauthorised, or unlawful access, disclosure, alteration, loss, or destruction of your personal data.

Warnings. We advise you to remain cautious about what you choose to make public on the internet, particularly regarding personal data, including private or sensitive information made public at your initiative, or inferred from your contributions, comments, and positions of any kind on the Website or on social media groups and/or conversations with other Website users.

HTTPS Protocol. The Website URL begins with "https" and is accompanied by a closed padlock or a key at the bottom right of your browser. This allows you to verify that you are in a secure browsing zone, particularly when your credit card number is requested. HTTPS security standards are high and are applied to data storage.

Data breach. In the event of an incident leading to the modification, loss, or unauthorised access to Data, we undertake to:

Investigate the causes of the incident;
Take the necessary measures to limit the negative effects and harm resulting from the incident;
Notify the competent authority and/or affected individuals as soon as possible where required by law.

Under no circumstances shall the above commitments be construed as an acknowledgement of fault or liability regarding the occurrence of such an incident.

GENERAL PROVISIONS

Mandatory or optional nature. On the Website, you are informed of the mandatory nature of responses by the presence of an asterisk or other indication. In the event of an incomplete submission (e.g. registration, online order, information request, etc.), the Company reserves the right to request additional information or to technically prevent the form from being submitted.

Hyperlinks. The Website may provide links to other websites, applications, and services operated by third parties. We are not responsible for the processing of personal data carried out by these third-party sites; users are advised to consult their privacy policies. This Policy applies solely to the Company's activities.

Scope. This Policy is not exhaustive of all processing activities, and we reserve the right to supplement it by any means.

Language. This Policy is drafted in French. In the event of a translation into one or more languages, only the French text shall prevail in the event of a dispute.

Non-waiver. The temporary or permanent non-application of one or more clauses of this Policy shall not constitute a waiver of the remaining clauses, which shall continue to have effect.

Amendments and updates. We reserve the right to modify this privacy policy. Data subjects will be notified where required by applicable regulations. The update date is shown at the top of this page, and we encourage you to review it regularly.

Privacy Policy