Privacy policy 
Introduction
In the context of its activity, Tooltip Media, whose head office is located at 184 Route de la Frasse, Chamonix-Mont-Blanc, is required to collect and process information, some of which is qualified as "personal data". Tooltip Media attaches great importance to the respect of privacy, and only uses data in a responsible and confidential manner and for a specific purpose.
Definitions:
The Publisher: The person, natural or legal, who publishes the online public communication services.
The Site: All websites, web pages and online services offered by the Publisher.
The User: The person using the Site and the services.
Type of data collected
On the tooltipmedia.com website, there are 2 types of data that may be collected:
- The data transmitted directly
These data are those that you transmit to us directly, via a contact form or by direct contact by email. The fields "first and last name", "company or organization" and "email" are mandatory in the contact form. - Data collected automatically
During your visits, once you have given your consent, we may collect "web analytics" type information relating to your browsing, the duration of your visit, your IP address, your browser type and version. The technology used is the cookie.
Legal basis
Personal data are collected only after mandatory consent of the user. This consent is validly collected (buttons and check boxes), free, clear and unequivocal.
Cookies
Cookie retention time
In accordance with the recommendations of the CNIL, the maximum duration of conservation of cookies is 13 months after their first deposit in the terminal of the User, as well as the duration of the validity of the User's consent to the use of these cookies. The lifetime of cookies is not extended with each visit. The User's consent must therefore be renewed at the end of this period.
Purpose of cookies
Cookies may be used for statistical purposes, in particular to optimize the services rendered to the User, based on the processing of information concerning the frequency of access, the personalization of the pages as well as the operations carried out and the information consulted. You are informed that the Publisher may place cookies on your terminal. The cookie records information relating to navigation on the service (the pages you consulted, the date and time of the consultation, etc.) which we can read during your subsequent visits.
User's right to refuse cookies
You acknowledge that you have been informed that the Publisher may use cookies. If you do not want cookies to be used on your device, most browsers allow you to disable cookies through the settings options.
List of cookies used on the site :
- Google Analytics cookies (exhaustive list) : Web traffic analysis
- tooltip-rgpd: Keeps track of the fact that you accept cookies so that you won't be bothered the next time you visit.
Disclosure of personal data to third parties
No communication to third parties
Your data will not be disclosed to third parties. However, you are informed that your data may be disclosed in application of a law, a regulation or by virtue of a decision of a competent regulatory or judicial authority.
Purpose of the re-use of the personal data collected
Carry out operations related to prospecting
- Management of technical prospecting operations (including technical operations such as normalization, enrichment and de-duplication)
- The selection of persons to carry out loyalty, canvassing, surveys, product testing and promotional activities. Except with the consent of the persons concerned obtained under the conditions provided for in Article 6, these operations must not lead to the establishment of profiles likely to reveal sensitive data (racial or ethnic origins, philosophical, political, trade union or religious opinions, sex life or health of persons)
- The realization of solicitation operations
Geolocation
Geolocation for service delivery purposes
We collect and process your geolocation data in order to provide you with our services. We may make use of personal data in order to determine your geographical position in real time. In accordance with your right of opposition provided by the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the possibility, at any time, to deactivate the functions relating to the geolocation.
Geolocation for cross-referencing purposes
We collect and process your geolocation data in order to allow our services to identify the points of intersection in time and space with other Users of the service in order to present you with the profile of the crossed Users. In accordance with your right of opposition provided for by the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the possibility, at any time, to deactivate the functions relating to geolocation. You acknowledge that the service will no longer be able to present you with profiles of other Users.
Geolocation with provision of partners for referencing and aggregation (with opt-in)
We may collect and process your geolocation data with our partners. We commit ourselves to anonymize the data used. In accordance with your right of opposition provided for by the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the possibility, at any time, of deactivating the functions relating to geolocation.
Collection of terminal data
Collection of profiling and technical data for service delivery purposes
Some of the technical data of your device is automatically collected by the Site. This information includes your IP address, Internet service provider, hardware configuration, software configuration, browser type and language... The collection of this data is necessary for the provision of the services.
Collection of technical data for advertising, commercial and statistical purposes
Technical data from your device is automatically collected and stored by the Site for advertising, marketing and statistical purposes. This information helps us to personalize and continually improve your experience on our Site. We do not collect or store any personal data (name, first name, address...) that may be attached to technical data. The data collected may be sold to third parties.
Technical data retention
Duration of technical data retention
The technical data are kept for the time strictly necessary to achieve the purposes mentioned above.
Retention period for personal data and anonymization
Data retention for the duration of the contractual relationship
In accordance with article 6-5° of the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, the personal data being the subject of a treatment are not preserved beyond the time necessary to the execution of the obligations defined at the time of the conclusion of the contract or of the predefined duration of the contractual relation.
Retention of anonymized data beyond the contractual relationship / after deletion of the compte
We keep personal data for the time strictly necessary to achieve the purposes described in these GTU. Beyond this period, it will be anonymized and kept for statistical purposes only and will not be used in any way whatsoever.
Deleting data after account deletion
Means of data purging are set up in order to provide for the effective deletion of data as soon as the period of conservation or archiving necessary for the achievement of the determined or imposed purposes is reached. In accordance with the law n°78-17 of January 6, 1978 relating to data processing, the files and freedoms, you have moreover a right of suppression on your data which you can exert constantly by taking contact with the Editor.
Data deletion after 3 years of inactivity
For security reasons, if you have not logged in to the Site for a period of three years, you will receive an e-mail inviting you to log in as soon as possible, otherwise your data will be deleted from our databases.
Account deletion
Deletion of the account on request
User may delete his or her Account at any time by simply requesting it from Publisher OR by using the Account deletion menu in the Account settings, if applicable.
Account deletion in case of TOS violation
If you violate any provision of the TOS or any other document incorporated herein by reference, Publisher reserves the right to terminate or restrict, without prior notice and in its sole discretion, your use of and access to the Services, your account and all Sites.
Indications in case of a security breach detected by the Editor
Information to the User in case of a security breach
We undertake to implement all appropriate technical and organizational measures in order to guarantee a level of security adapted to the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of personal data concerning you.
In the event that we become aware of unlawful access to your personal data stored on our servers or those of our service providers, or unauthorized access resulting in the risks identified above, we will:
- Notify you of the incident as soon as possible;
- Examine the causes of the incident and inform you;
- Take reasonable steps to mitigate any adverse effects and damages that may result from such incident
Limitation of liability
Under no circumstances may the commitments defined in the above point concerning notification in the event of a security breach be assimilated to any acknowledgement of fault or responsibility for the occurrence of the incident in question.
Transfer of personal data abroad
No transfer outside the European Union
The Publisher undertakes not to transfer the personal data of its Users outside the European Union.
Modification of the T&Cs and the privacy policy
In case of modification of the present T&C, commitment not to lower the level of confidentiality in a substantial way without prior information of the persons concerned.
We undertake to inform you in the event of a substantial change to these TOS, and not to lower the level of confidentiality of your data substantially without informing you and obtaining your consent.
Applicable law and methods of appeal
Arbitration clause
You expressly agree that any dispute that may arise as a result of these TOU, including its interpretation or performance, shall be subject to arbitration under the rules of the mutually agreed upon arbitration platform, to which you shall adhere without reservation.
Data Portability
Data Portability
The Publisher undertakes to offer you the possibility of having all your data returned to you on request. The User is thus guaranteed a better control of his data, and keeps the possibility of reusing them. This data must be provided in an open and easily reusable format.
Contact for data protection officer
Juan Pablo Cadavid – Email : juan(at)tooltipmedia.com
