This Personal Data Privacy Policy applies to the processing of Data that we perform concerning you, notably through our website (hereinafter designated by “Website” or “Our Website”).
In particular, it describes the operations carried out with your personal Data and your rights in respect of your Data, as well as the terms and conditions for exercising these. This Personal Data Privacy Policy complements the Terms and Conditions of the Website and any other terms applicable to the Unpose Media services.
We ask you to regularly review this Personal Data Privacy Policy to keep up to date with any changes that may affect the latter.
1. DEFINITIONS
In this Personal Data Privacy Policy, each term with a capital letter has a very specific meaning. You may find the definitions of these terms below:
Client: means a natural person or legal entity (represented by its legal representative or any other duly authorized person), professional or individual, requesting the services of UNPOSE MEDIA either for itself or on behalf of its own clients (which may be natural Data Subjects or legal entities, professionals or individuals – hereafter the “End Clients” or “End Client”).
Data or Personal Data: means any information relating to a Data Subject, including any information deemed personal information under the Applicable regulation regarding data protection;
Applicable regulation regarding data protection: means Regulation (EU) 2016/679 of the European Parliament and the Council as well as act no. 78-17 of 6 January 1978 as modified and any other legal provisions applicable and relating to the Processing and/or protection of personal data;
Processor: means the natural person or legal entity, public authority, service or any other organisation which, alone or jointly with others, determines the purposes and means of processing Personal Data;
Services: means the photography services delivered by UNPOSE MEDIA to its Clients or End Clients via the Website;
Processing or process: means any operation or set of operations carried out, whether or not by means of automated processes and applied to Personal Data, such as collection, registration, organisation, retention, adaptation or modification, extraction, consultation, use, disclosure by transmission, distribution or any other form of making available, matching or interconnection as well as locking, deletion or destruction;
User: individual browsing on the Website.
2. COLLECTION OF YOUR PERSONAL DATA
2.1 IDENTITY AND CONTACT DETAILS OF THE PROCESSOR
Personal Data is collected and processed by:
The microentreprise UNPOSE MEDIA (hereafter “UNPOSE MEDIA” or the “Processor”)
Registered in the name of Ciprian Olteanu with the identification number SIREN 830487427
Phone number: +33 1 89 16 71 96
2.2 CONTACT DETAILS OF THE PERSON IN CHARGE OF DATA PROTECTION
You may contact the person in charge of Data Protection for UNPOSE MEDIA at the following email address: [email protected].
2.3 PERSONAL DATA COLLECTION
We may collect your Data in different ways, particularly when you register with UNPOSE MEDIA as a Client, when you browse our Website, when you contact us via our Website (subsite “Contact”), but also in our communication by letter, email or telephone.
We also reserve the right to link and/or combine the Data concerning you that we collect through these different means.
2.4 THE PURPOSE OF DATA PROCESSING
We process the Data processing for the following objectives (purposes):
We process the Data processing for the following objectives (purposes):
– You are a Client or End Client: UNPOSE MEDIA processes your Data to:
• Manage your registration;
• Send you communications and information, notably for marketing purposes;
• Manage our relationship with you (notably by keeping your account up to date), orders you have placed with UNPOSE MEDIA, contracts you sign with UNPOSE MEDIA;
• Manage and examine the comments you submit regarding the Services (in order to improve the Unpose Media services).
– You are a User of the Website: UNPOSE MEDIA processes your Data to:
• Access a Website allowing you to use the Services that we offer and improve your user experience;
• Improve the Website’s content;
In all cases UNPOSE MEDIA may be called on to process your Data to:
• Manage requests of the Data Subjects concerned to exercise rights regarding their Personal Data;
• Carry out advertising or prospecting campaigns.
This processing is implemented on the following legal basis:
• The performance of the contractual relationship that links you to UNPOSE MEDIA for the following purposes: account management, management of UNPOSE MEDIA’s relationship with Clients; availability of the Website.
• The legitimate interest of UNPOSE MEDIA:
o To serve its business purposes and develop its Service offer, for the following purposes: event management; management of its relationship with Clients; and sending communications and information, including for marketing purposes.
o To promote its activities and Services, for the following purposes: sending communications and information, including for marketing purposes, carrying out advertising or prospecting campaigns.
o To respond to requests as part of its activities for the following purpose: Management of requests and responses posted on the Website.
• Compliance with a legal obligation, for the management of requests of the Data Subjects which want to exercise their rights.
• Your consent for certain prospecting or advertising campaigns.
3. COMPULSORY OR OPTIONAL NATURE OF THE COLLECTION
UNPOSE MEDIA informs you when the provision of information is compulsory. If you do not provide this “compulsory” information, UNPOSE MEDIA may be unable to provide the relevant services or answer any queries.
If the information requested is not mandatory, the fields of the relevant form will be identified as such. It is up to you to choose to fill them in or not.
4. COOKIES
When viewing the Website, and subject to your browser settings, cookies may be dropped on your browser when you connect via a terminal (computer, tablet, smartphone, etc).
Cookies are text files used to recognise your browser throughout the validity period of the cookie concerned and may be used to optimise the use of the Website and personalise the content displayed.
The Website uses Technical cookies to allow use of the Website and its functionalities. You may object to the use of such cookies and delete them at any time by going through your browser settings; however, we inform you that the use of the Website may be impaired.
The cookies will be valid for 13 months.
5. INFORMATION WE SHARE
We do not disclose or share the Personal Data we collect except in the following cases:
• To internal teams who need to access such Personal Data for the purposes listed above;
• To our service providers as part of their services in connection with the purposes listed above;
• If you agree to share such Personal Data with third parties, such as social networks;
We may share aggregated, pseudonymised, or even anonymised information, which is not identifiable, in the context of statistical analyses of our business objectives, which includes the number of visitors to Our Website and the number of clicks on our website and our emails.
6. DATA TRANSFER OUTSIDE OF THE EUROPEAN UNION
Whether you are a Client or End Client, your Data may be transferred outside of the European Union either to service providers (United States of America), or if you are a Client or an End Client located outside of the European Union.
In such cases, we undertake to take the appropriate measures (such as the signature of standard contractual clauses of the European Commission), except if there is a legal exemption to do so.
To find out more information about this, you may contact the person in charge of Data Protection for UNPOSE MEDIA.
7. INFORMATION RELATING TO THE DATA RETENTION PERIOD
UNPOSE MEDIA has set forth retention periods for your Data, based on the processing objective (its purpose) and taking into account its legal obligations and needs in terms of evidence (i.e. the existence of a contractual relationship).
Generally speaking, your Data is kept by UNPOSE MEDIA for the time needed and for the purpose for which it has been collected. Your Data will then be archived for the statutory limitation period applicable in order to allow UNPOSE MEDIA to meet its legal obligations.
8. SOCIAL NETWORKS AND CONTENT GENERATED BY USERS
Our Website makes reference to UNPOSE MEDIA pages and accounts on different social networks. We draw your attention to the fact that the content presented on these social platforms may be viewed by the public. This is why you must be vigilant when you submit Personal Data via such platforms. UNPOSE MEDIA cannot be held liable for actions taken by third parties if you post Data on one of UNPOSE MEDIA’s social media accounts.
9. HOW TO EXERCISE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
In accordance with applicable Regulation regarding data protection and under the conditions provided for by the said Regulation, in respect of your Personal Data you have a right:
• of access (in particular to establish what Personal Data is processed by UNPOSE MEDIA);
• of rectification (to rectify Personal Data that is incorrect or no longer up to date);
• of deletion (when you meet the conditions provided for by the Regulation and you wish for UNPOSE MEDIA to no longer process all or part of your Personal Data);
• of portability (when you meet the conditions provided for by the Regulation and you wish to recover your Personal Data or have it recovered by a third party);
• of limitation in respect of Personal Data processing (when you meet the conditions provided for by the Regulation and you wish for the Processing of your Personal Data to be suspended owing to an event referred to by the said Regulation);
• of opposition for reasons related to your particular situation (when you meet the conditions provided for by the Regulation and you no longer wish for your Personal Data to be processed by UNPOSE MEDIA);
Moreover, at any time and without justification you have the right to opt out of the processing of your Personal Data for commercial prospecting purposes, including profiling and have a right to withdraw any consent given to UNPOSE MEDIA.
In some cases, we may ask you to justify your identity (copy of national identity card or passport) in order to ensure that you are indeed the relevant Data Subject. Your identity document will be kept for the period needed to process your request.
You may exercise these rights by sending a request to the person in charge of Data Protection by email ([email protected]) or by letter for the attention of DPO of UNPOSE MEDIA, 121 rue des Charmettes – 69006 LYON.
Moreover, you may also file a claim with the CNIL (French information commissioner’s office) i.e.:
• by letter: 3 Place Fontenoy – TSA 80715 – 75334 Paris Cedex 07.
10. CHANGES TO THE PERSONAL DATA PROTECTION POLICY
This Personal Data Protection Policy may be updated periodically to inform any individual of changes that have occurred in our practices regarding Personal Data processing. These changes will be published on our Website if applicable.
11. CONTACT US
For any additional information on the protection of your Personal Data, you may contact us:
• via the Website: in the subsite “Contact”;
• by telephone at: +33 1 89 16 71 96;
• by post: UNPOSE MEDIA – 121 rue des Charmettes – 69006 LYON.
Last update: 08 July 2021