Privacy policy.
LUCIDITY BUSINESS ENGLISH
Sole proprietorship
Head office: 244 rue Chantepie, Prévessin-Moëns, 01280, France
INSEE : 91012533500018
This privacy policy (hereinafter referred to as the "Privacy Policy") defines the legal framework for the collection, use and processing by LUCIDITY BUSINESS ENGLISH (hereinafter referred to as " LBE ") of personal data concerning users browsing and/or using the services offered by the web platform (hereinafter referred to as the "Users") accessible at www.luciditybusinessenglish.com (hereinafter referred to as the "Platform").
Under the terms of the Privacy Policy, the data controller of personal data is : LBE.
The provision of the Personal Data collected within the framework of the Privacy Policy, is mandatory and necessary for the treatment and for the supply of the services provided by LBE
via the Platform (hereafter referred to as the "Services"). The lack of information prevents the proper functioning and supply of the proposed Services.
LBE is committed to respecting the applicable regulations in terms of personal data protection and in particular the obligations arising from European regulation n° 2016/679 on the protection of personal data ("RGPD").
LBE collects Personal Data only in compliance with the terms of this Privacy Policy and any legal and reasonable instructions given by the User at any time.
ARTICLE 1: INFORMATION COLLECTED
1.1 Throughout the use of the Platform and the Services, LBE may collect any information, directly or indirectly identifying the User, necessary for the creation of an account on the Platform and necessary for the proper functioning of the Platform (hereinafter referred to as "Personal Data").
When filling in his information to request a quote, the User expressly consents to the processing of his Personal Data within the limits of a processing strictly necessary for the proper functioning of the Platform and the Services.
The information collected is mandatory. This information is necessary for the processing and provision of the Services. The lack of information prevents the proper functioning of the Services.
1.2 Personal Data may be collected directly when the User communicates them to LBE by means of information forms, contact requests, orders, publication of opinions on the Services provided and reporting of illicit content.
This includes Personal Data relating to the User's identity and in particular: his or her title, surname, first name, e-mail address, postal address and telephone number.
1.3 In order to improve the services of the Platform, LBE (including its technical service providers) may automatically collect:
- Data relating to browsing, in particular the anonymized IP address, the browser used, the duration of browsing, the operating system used, the language and the pages viewed ;
- Data relating to the use of the Platform by the User, including traffic data, number of notifications, number of visits, number of data updates and any other data or communication resources that the User uses when accessing the Platform.
1.4 LBE grants itself the right to review, scan or analyze communications exchanged between LBE and Users via the Platform for the purposes of fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and User support.
The information of Personal Data collected for these purposes is mandatory and strictly necessary for the proper functioning of the Platform. Otherwise, the Services cannot be provided.
ARTICLE 2: USE OF PERSONNAL DATA
LBE uses, stores and processes Personal Data, in order to power, understand, improve and develop the Platform, to create and maintain a trusted environment with Users as well as to comply with its legal obligations.
Personal Data is processed primarily for the purpose of enabling Users to properly access and use the Platform and Services, and to enable LBE to manage course orders placed through the Platform.
Personal Data may also allow LBE to improve its service by analyzing User behavior when using the Platform.
LBE uses Users' Personal Data for the following purposes:
Processing purposes: Management of contact requests
Legal basis: The processing is necessary for the execution of the contract concluded between the User and LBE
Processing purposes: Taking orders into account
Legal basis: The processing is necessary for the execution of the contract concluded between the User and LBE
Processing purposes: Order management and processing
Legal basis: The processing is necessary for the execution of the contract concluded between the User and LBE
Processing purposes: Invoicing
Legal basis: The processing is necessary for the execution of the contract concluded between the User and LBE
Processing purposes: Information on LBE, Services, and activities
Legal basis: The processing is necessary for the legitimate interests pursued by LBE
Processing purposes: Response to possible questions/complaints from Users
Legal basis: The processing is necessary for the execution of the contract concluded between the User and LBE
Processing purposes: Elaboration of commercial statistics
Legal basis: The processing is necessary for the legitimate interests pursued by LBE
Processing purposes: Management of requests for access, portability, deletion, rectification and opposition rights
Legal basis: The processing responds to a legal obligation
Processing purposes: Management of unpaid bills and disputes
Legal basis: The processing is necessary for the execution of the contract concluded between the User and LBE
Processing purposes: Profiling
Legal basis: The processing is necessary for the legitimate interests pursued by LBE
Users' personal data are processed by LBE and by service providers that support LBE's activity such as the Site host, acting as a subcontractor.
ARTICLE 3: RETENTION OF PERSONNAL DATA
Personal Data is kept as long as necessary, to achieve the purpose for which LBE holds this data, in order to meet the needs of Users or to fulfill its legal obligations.
To establish the duration of the retention of personal data, LBE applies the following criteria:
- In case of order of Services, personal data are kept for the duration of the contractual relationship and for the legal prescription periods;
- The data collected from Users is also used for commercial prospecting purposes and is kept for three years after collection or the last contact with the User;
- If the User participates in a promotional offer, personal data is kept for the duration of the promotional offer concerned;
- If the User makes a request to LBE, personal data will be kept for the time necessary to process the request;
- If cookies are placed on the User's computer, personal data will be retained for any period of time defined in accordance with applicable regulations.
At the end of the above-mentioned periods and in any case from the deletion of the User's account from the Platform or at the latest six (6) years after the end of the use of the Services by the User, the personal data will be destroyed or LBE will proceed to their anonymization.
However, LBE may keep certain personal data collected on separate storage spaces in order to comply with its legal or regulatory obligations.
ARTICLE 4: TRANSFER OF PERSONNAL DATA
4.1 LBE may disclose Personal Data to administrative and judicial authorities, or to authorized third parties, if required or permitted by law, or if such disclosure is reasonably deemed necessary: (i) to comply with LBE's legal obligations, (ii) to comply with the judicial process and to pursue claims against LBE, (iii) to respond to verified requests in connection with a judicial investigation or alleged or suspected illegal activity or any other activity that may expose LBE to legal liability.
4.2 LBE has the right to subcontract all or part of the execution of the Services in compliance with the legal provisions in force.
In this context, LBE does not transfer Personal Data to third parties established outside the European Union that do not offer an adequate level of protection with regard to the legal requirements for the protection of Personal Data.
4.3 The subcontractor will be authorized to process on behalf of LBE, the Personal Data necessary to provide the Services.
LBE represents that it:
- To have delivered in writing any instructions regarding the processing of Personal Data by the subcontractor;
- To ensure, in advance and throughout the processing, that the subcontractor complies with the obligations set forth in the European Regulation on the protection of Personal Data;
- Supervise the processing, including conducting audits and inspections of the sub-processor.
LBE undertakes that the sub-processor will:
- Processes Personal Data only for the sole purpose(s) that is/are the subject of the subcontract;
- Process the Personal Data in accordance with LBE's instructions;
- Guarantees the confidentiality of the Personal Data processed;
- Has undergone the necessary training on the protection of Personal Data;
- Take into account, with respect to its tools, products, applications or services, the principles of protection of Personal Data by design and protection of Personal Data by default;
- Inform LBE immediately if it considers that an instruction constitutes a violation of the European Data Protection Regulation or any other provision of Union or Member State law relating to the protection of Personal Data.
4.4 Personal Data may be transmitted to technical service providers, for the sole purpose of the proper execution of the Services, or to its various suppliers such as payment solution providers.
Personal Data may also be transmitted to commercial partners that allow LBE to properly execute orders, their management, processing and payment under the contractual conditions signed between the partner and LBE that cannot derogate from the conditions of this Privacy Policy.
Only with the express consent of the Users, LBE may re-use the Personal Data or transmit them to partner companies for the purpose of sending commercial information by e-mail. If Users wish to receive such messages, they must check the box provided for this purpose.
4.5 LBE uses the services of the company SQUARESPACE as a host for the Users' data. The servers are located in Ireland and the United States.
Pursuant to Decree No. 2011-219 of February 25, 2011 on the retention and communication of data identifying any person who has contributed to the creation of content posted online, the User is informed that the Site host is obliged to retain for a period of one year from the day of creation of content, for each operation contributing to the creation of a content:
- The identifier of the connection at the origin of the communication;
- The identifier assigned by the information system to the content, object of the operation;
- The types of protocols used for the connection to the service and for the transfer of the contents;
- The nature of the operation;
- The date and time of the operation;
- The identifier used by the author of the operation when he/she has provided it.
ARTICLE 5: PROTECTION OF PERSONAL DATA – USERS’ RIGHTS
5.1 LBE ensures that Personal Data is adequately and appropriately secured, and has taken the necessary precautions to preserve the security and confidentiality of the data and to prevent it from being distorted, damaged or communicated to unauthorized persons.
When LBE notes a violation of rights in the context of the processing of Personal Data, this violation will be notified to the French supervisory authority (CNIL) within a period that cannot be longer than seventy-two (72) hours after becoming aware of it.
Any violation relating to the processing of Personal Data will be notified by e-mail, within one (1) month, by LBE to the User concerned.
5.2 Personal Data provided by the User will be destroyed no later than six (6) years after the User has finished using the Services. LBE reserves the right to keep certain data in order to justify, if necessary, the perfect execution of its contractual or legal obligations. The data thus retained will be limited to what is strictly necessary.
5.3 In all cases, Users have the right to access, rectify, modify, oppose, portability and delete their Personal Data by writing to the following address lucinda@luciditybusinessenglish.com indicating his name, first name, e-mail and address.
In accordance with the regulations in force, LBE may ask the User for proof of identity.
The User will be able to retrieve his Personal Data in an open and readable format. The right to portability is limited to the data provided by the User concerned. It applies on the basis of the User's prior consent. LBE undertakes to transfer, upon request, within one (1) month, any document collecting Personal Data to the User in order to implement the right to portability. The costs related to the recovery of the data are at the expense of the User making the request.
ARTICLE 6: USE OF COOKIES
6.1 When Users order Services and Products on the Site, LBE may use cookies.
Cookies are small text files used to store small information. Cookies are stored on your device when the Website is loaded on your browser. These cookies help LBE to make the website work properly, to make the website more secure, to provide a better user experience and to understand how the website works and to analyse what works and where it needs to be improved.
6.2 Some cookies are essential for the User to enjoy all the features of the website and do not collect confidential information about Users.
In accordance with CNIL deliberation no. 2013-378 of December 5, 2013, LBE informs Users that cookies record certain information that is stored in the memory of their computer hardware/equipment. This information is used to improve the use and operation of the Site, but also to understand how the Site is used by Users, as well as the tools and services that LBE makes available to them. An alert message informs everyone visiting the Site of the presence of these essential cookies.
6.3 The Site also uses third party cookies for non-essential purposes to understand how the Website functions and how the User interacts with the Website, to provide advertisements that are relevant to the User and in the aggregate to provide a better and improved User experience and to speed up future User interactions with the Website.
The third party cookies on the Site are as follows:
- Statistical Cookies: These cookies store information such as the number of visitors to the Site, the number of unique visitors, the pages of the Site that were visited, the source of the visit, etc. This data helps LBE understand and respond to the needs of the User. This data helps LBE understand and analyze the performance of the Site and how it can be improved.
- Functional Cookies: These are cookies that help with certain non-essential features of the Site, including embedding content such as videos or sharing content on the Site.
- Preference Cookies: These cookies help LBE to store the browsing settings and preferences of Users so that they have a better experience on future visits to the Site.
6.4 To ensure the User's free, informed and unequivocal consent, the User visiting the home page or another page of the Site directly from a search engine will be informed of:
- The precise purpose of the cookies used;
- Of the possibility to oppose these cookies and to change the parameters by clicking on a link present in the banner;
- And of the fact that the continuation of his navigation does not mean that he agrees to the deposit of cookies on his terminal.
The banner will not disappear until the user accepts or refuses the deposit and reading of cookies
6.5 Unless the User gives his prior consent, cookies will not be deposited or read:
- If he/she goes to the Site (home page or directly to another page of the Site) and continues his/her navigation: a simple absence of action cannot be considered as a manifestation of will;
- Or if he clicks on the link in the banner allowing him to set the parameters of the cookies and, if necessary, refuses the deposit of cookies.
6.6 The User may at any time choose to deactivate cookies and other tracers. The User's browser can be configured to notify him/her of cookies that are deposited in his/her terminal and to ask him/her to accept them or not.
The configuration of each browser is different. It is described in the browser's help menu, which will allow the User to know how to modify his wishes regarding cookies.
"Firefox: https://support.mozilla.org/fr/kb/cookies-informations-sites-enregistrent
ü Click on the menu button and select "Options".
ü Select the "Privacy" panel.
ü Set the "Retention Rules" menu to "Use custom settings for history".
ü Uncheck the "Accept cookies" box.
ü Any changes you have made will be automatically saved.
"Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7
ü Click on the Tools button, then on "Internet Options".
ü Click on the "Privacy" tab, then under "Settings", move the slider up to block all cookies or down to allow all cookies, then click OK.
"Google Chrome: https://support.google.com/chrome/answer/95647?hl=fr
ü Select the Chrome menu icon.
ü Select "Settings."
ü At the bottom of the page, select "Show advanced settings."
ü In the "Privacy" section, select "Content Settings."
ü Select "Block all sites from storing data."
ü Select OK.
"Safari: https://www.apple.com/legal/privacy/fr-ww/cookies/
ü Click "Settings" > "Safari" > "Privacy" > "Cookies and Website Data."