Privacy policy
DEVELEGANT.COM PRIVACY POLICY
PREAMBLE
Cyril Seguenot, a sole proprietorship, is committed to ensuring that the collection and processing of your data is carried out lawfully, fairly and transparently, in accordance with the General Data Protection Regulation (RGPD) and the French Data Protection Act of 1978, as amended. The collection of personal data of its prospects and customers is limited to what is strictly necessary, in accordance with the principle of data minimization, and indicates what purposes are pursued by the collection of this data, whether providing this data is of an optional or mandatory nature to manage requests and who will be able to see it.
Article I. DEFINITIONS
The Publisher: The individual or legal entity that publishes online public communication services, i.e.: Mr Cyril SEGUENOT
Mr Cyril SEGUENOT operating as a sole trader under the SIRET number 80898658200035 residing at 15 rue des Feuillards - 87500 Saint-Yrieix-la-Perche.
Contact address: contact [at] develegant [dot] com
The Site: All the sites, web pages and online services offered by the Publisher, who operates the sites accessible from the following URL addresses:
https://develegant.com The User: The person using the Site and services.
Article II. NATURE OF DATA COLLECTED
As part of the use of the Sites, in order to provide an online training service, the Publisher is likely to collect the following categories of data concerning its Users:
Civil status, identity and identification data (surname, first name, e-mail address, profession, telephone number, etc.)
Data relating to personal life, excluding sensitive or dangerous data (family situation, etc.)
Professional data (CV, education, professional training, awards, etc.)
Connection data (IP addresses, event logs, etc.)
Location data (movements, GPS data, GSM, etc.)
The Publisher undertakes to keep a written record of all categories of processing activities carried out in its capacity as data controller for the above-mentioned data.
Article III. INFORMATION AND USERS' RIGHTS
The Publisher hereby clearly informs you of the personal data processing activities it carries out in the course of its business, and how the data is collected, used and protected.
All Users have the right to ask the data controller, i.e. the Publisher :
Access to personal data provided; Rectification or deletion of personal data; Limitation of the processing of personal data; Opposition to processing; Data portability; Complaints to the CNIL.
Article IV. SUBCONTRACTING
The Publisher undertakes to ensure that any subcontractor provides sufficient contractual guarantees as to the implementation of appropriate technical and organizational measures, so that the processing complies with the requirements of the European Data Protection Regulation.
The Publisher may use one or more subcontractors to carry out specific processing activities, which will be subject to the conditions of this Policy. Any subcontractor will not be permitted to itself call upon a subcontractor without the prior written authorization of the Publisher.
Article V. COMMUNICATION OF PERSONAL DATA TO THIRD PARTIES
Communication to authorities on the basis of legal obligations
On the basis of legal obligations, your personal data may be disclosed in application of a law, a regulation or by virtue of a decision by a competent regulatory or judicial authority.
In general, we undertake to comply with all legal rules that may prevent, limit or regulate the dissemination of information or data and in particular to comply with Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms and the European Union's General Data Protection Regulation (RGPD).
Disclosure to third parties based on account settings
Your personal data is strictly confidential and may not be disclosed to third parties, except with your express consent obtained via your account settings.
Communication to third parties in aggregated and anonymized form
Your personal data may be used to enrich our databases. It may be passed on to third parties after being anonymized and exclusively for statistical purposes.
Commitment to the applicability of the privacy policy
Should your personal data be communicated to a third party, the Publisher will ensure that the latter is bound to apply the same confidentiality conditions as the Site.
Article VI. PRIOR NOTICE FOR THE TRANSFER OF PERSONAL DATA TO THIRD PARTIES IN THE EVENT OF A MERGER / ACQUISITION
Prior notice and possibility of opt-out before and after merger / acquisition
In the event that we involved in a merger, acquisition or any other form of transfer of assets, we commit to maintaining the confidentiality of your personal information and to notifying you before it is transferred or subject to new confidentiality rules.
Article VII. DATA AGGREGATION
Aggregation with non-personal data
We may publish, disclose and use aggregated information (information about all our Users or specific groups or categories of Users that we combine in such a way that an individual User can no longer be identified or referred to) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes and other business purposes.
Article VIII. COLLECTION OF PERSONAL DATA
Registration and prior identification for service provision
Use of the Site requires prior registration and identification. Your personal data (surname, first name, postal address, e-mail) are used to fulfil our legal obligations resulting from the delivery of products and/or services as provided for in the order.
You will not provide false nominative information or create an account for another person without their authorization. Your contact information must always be accurate and up-to-date.
Article IX. COLLECTION OF TERMINAL DATA
Collection of profiling and technical data for service provision purposes Some technical data about your device is automatically collected by the Site. This information includes in particular your IP address, Internet service provider, hardware configuration, software configuration, browser type and language, etc. The collection of this data is necessary for the provision of services.
We do not collect or store any nominative data (surname, first name, address, etc.) that may be attached to technical data.
Article X. COOKIES
Cookie retention period
In accordance with CNIL recommendations, cookies are kept for a maximum of 13 months after it is first deposited in the User's terminal, as is the period of 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 services rendered to the User, based on the processing of information concerning access frequency, page personalization, operations carried out and 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 have consulted, the date and time of consultation, etc.) which we can read during your subsequent visits.
The User's right to refuse cookies, deactivation of which may result in the service not working properly
You acknowledge that you have been informed that the Publisher may use cookies, and authorize it to do so. If you do not wish cookies to be used on your terminal, most browsers allow you to disable cookies via the settings options. However, please note that some services may no longer function correctly.
Possible association of cookies with personal data to enable service operation
The Publisher may collect browsing information through the use of cookies.
Translated with www.DeepL.com/Translator (free version)
Article XI. RETENTION OF TECHNICAL DATA
Technical data retention period
Technical data is kept for the time strictly necessary to achieve the above-mentioned purposes.
Article XII. RETENTION PERIOD FOR PERSONAL DATA (AND ANONYMIZATION)
Retention of data for the duration of the contractual relationship In accordance with ## Article 6-5° of the French Data Protection Act no. 78-17 of January 6, 1978, personal data that is the subject of processing shall not be kept beyond the time required to fulfill the obligations defined when the contract was concluded, or beyond the predefined duration of the contractual relationship.
Retention of anonymized data beyond the contractual relationship / after account deletion
We retain personal data for the time strictly necessary to achieve the purposes described in this Policy. After this period, the data will be anonymized and stored exclusively for statistical purposes and will not be used in any way whatsoever.
Deletion of data after account deletion
Means of data purging are put in place in order to provide for the effective deletion of data as soon as the retention or archiving period necessary for the fulfillment of the determined or imposed purposes has been reached. In accordance with the French Data Protection Act no. 78-17 of January 6, 1978, you also have the right to delete your data, which you may exercise at any time by contacting the Publisher.
Deletion of data after 3 years of inactivity
For security reasons, if you have not logged on to the Site, or if you have not engaged in active behavior (clicked on a link) for a period of three years, you will receive an e-mail inviting you to log on as soon as possible, failing which your data will be deleted from our databases.
Article XIII. ACCOUNT DELETION
Account deletion on request
The User may delete his or her Account at any time, by simple request to the Publisher OR by using the Account deletion menu in the Account settings, if applicable.
Account deletion in the event of a breach of the Privacy Policy
In the event of any violation of any provision(s) of this Agreement or any other document incorporated herein by reference, the Publisher reserves the right to terminate or restrict, without prior notice and at its sole discretion, your use of and access to the Services, your Account and all Sites.
Article XIV. INDICATIONS IN THE EVENT OF A SECURITY BREACH DISCOVERED BY THE EDITOR
Information to the User in the event of a security breach
We undertake to implement all appropriate technical and organizational measures using physical and logistical security measures in order to guarantee a level of security appropriate to the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of your personal data.
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 of unauthorized access resulting in the risks identified above, we undertake to :
Notify you of the incident as soon as possible if this is required by law; Examine the causes of the incident; Take all reasonable steps to mitigate any negative effects and damages that may result from the incident. Limitation of liability
Under no circumstances may the undertakings set out above concerning notification in the event of a security breach be assimilated to any admission of fault or responsibility for the occurrence of the incident in question.
Article XV. TRANSFER OF PERSONAL DATA ABROAD
Transfer of data to countries with an equivalent level of protection
The Publisher undertakes to comply with applicable regulations relating to the transfer of data to foreign countries, and in particular with the following procedures:
The Publisher transfers Users' personal data to countries recognized as offering an equivalent level of protection. The Publisher transfers the personal data of its Users outside countries recognized by the CNIL as having a sufficient level of protection: The Publisher has obtained authorization from the CNIL to proceed with this transfer. For a list of these countries: CNIL - Data protection worldwide
Article XVI. MODIFICATION OF THE PRIVACY POLICY
In the event of modification of the present policy, the Publisher undertakes not to lower the level of confidentiality substantially without prior information of the persons concerned.
Article XVII. PORTABILITY OF DATA
The Publisher undertakes to offer you the possibility of having all your personal data returned to you on request. The User is thus guaranteed better control of his or her data, and retains the possibility of reusing it. This data must be supplied in an open and easily reusable format, directly into the hands of another data controller where this is desired and technically possible.
Article XVIII. APPLICABLE LAW AND LANGUAGE
This Privacy Policy is governed by French law. It is written in French. In the event of translation into one or more languages, the French text shall prevail in the event of litigation. The nullity of a clause does not entail the nullity of the Privacy Policy. The temporary or permanent non-application of one or more of the clauses herein by the Publisher shall not constitute a waiver of the other clauses herein, which shall continue to have full effect.
Article XIX. DISPUTES AND JURISDICTION
ANY DISPUTE TO WHICH THE PRIVACY POLICY MAY GIVE RISE, IN PARTICULAR CONCERNING ITS VALIDITY, INTERPRETATION AND EXECUTION, THEIR CONSEQUENCES AND AFTERMATH, SHALL BE SUBMITTED TO THE COMPETENT COURTS WITHIN THE JURISDICTION OF THE CITY OF PARIS.