Data protection and cookie management policy

Website owner

CLEAN HORIZON CONSULTING

SAS with a capital of 15000 €.
SIRET : 517871182000

Code NAF : 7022Z

Head office : 12 rue de la Chaussée d'Antin 75009 Paris, France
Phone : +33 (0) 1 78 76 57 04
Email : contact @ cleanhorizon.com

This privacy policy defines the way in which CLEAN HORIZON uses and protects the information, and in particular the personal data, transmitted by the User when using the website (here in after referred to as the "Data").

In the context of this privacy policy, the terms "personal data" and "data controller" must be interpreted in accordance with the amended Law No. 78-17 of January 6, 1978, known as the "Informatique et Libertés" Act, and the European Regulation No. 2016/679 of April 27, 2016, known as the "European Data Protection Regulation".

Clean Horizon respects the will of the Users to protect their Data. During the use of the website, the User can be brought to provide certain information allowing his identification in a direct or indirect way. This information will be used in accordance with the present privacy policy and for the purposes of treatment consented by the User.

Definitions

Capitalized terms have the definitions given below. Words used in the singular or plural have the same definition.

· "Personal Data" means any information relating to an identified or identifiable natural person.

· "Data subject(s)" means a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

· "Data controller" means CLEAN HORIZON, which is the legal entity that alone determines the purposes and means of the processing.

· The "Customer Administrator" is the designated contact person within your company who can create accounts for their employees.

· "Service" means the services provided by CLEAN HORIZON.

· "Site" means all web pages and related resources accessible at https://www. cleanhorizon. com/

· "Processing" means any operation or set of operations that may or may not be carried out by automated means on personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

· "Cookie" refers to a small text file deposited on your terminal (for example a computer, a tablet, an ordiphone or "Smartphone", a connected television, a video game console connected to the Internet) when visiting a site or viewing an advertisement. It contains several data: the name of the server that deposited it, an identifier in the form of a unique number, possibly an expiration date. Cookies have different functions. Their purpose is to record the language settings of a site, to collect information about your navigation on the sites and to send you personalized services. Only the issuer of a cookie is likely to read, record or modify the information contained therein.

What Personal Information do we use?

We collect and use a limited amount of data from visitors to our website to help us improve the user experience, to manage the services we provide and to fulfill our obligations as a company, to send communications (informational, marketing and otherwise), and to comply with applicable laws and regulations. In addition to the personal data you provide directly to us, we may also process personal data about you obtained through our contact form, newsletter registration (TOP 5) or through our COMPASS platform through subscription subscriptions.

How do we collect Personal Information?

The Personal Data we process may be either directly provided by

You in the context of a purchase on the online store
By the contact person at your company when signing the subscription contract if you are designated as the customer administrator of the company's subscription or by the customer administrator designated by your company if you are a subscriber for access to online services via the COMPASS platform
Can be obtained from the following sources:

- Registration to the TOP5 : name and first name, email

- Contact form: first and last name, email and IP address

For users who register for the TOP 5 on our site, we also store the personal data indicated in their profile. All users can view, edit or delete their personal information at any time. Site managers can also view and edit the information.

Why and on what basis do we use your Data?

All information we collect from you is processed only if the processing is necessary and may be used to contact you in order to:

Meet your individual needs such as accessing your dedicated customer area (orders, subscriptions, etc)I
Improve the operation of our website and ensure its security
Manage our business relationship by personalizing our services
Provide you with access to the service ordered online (training, report, etc)
Send you newsletters to which you have subscribed
Provide you with the services included in your subscription to the online services according to the terms of the contract signed with your company (such as: sending of monthly market analysis reports)

Integrated content from other sites?

Articles on this site may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in the same way as if the visitor were visiting that other website.

These websites may use cookies or similar technologies to track your interactions with such embedded content, such as twitter or others.

How long do we keep Personal Data?

We keep your personal data only for as long as is necessary to fulfill the purpose for which it was collected (e.g., the TOP5 newsletter), in consideration of and in compliance with legal and regulatory requirements, including those applicable to data retention obligations. For example, in cases where the law requires the retention of data for audit or accounting purposes, or to enforce our contracts or manage disputes.

When personal data is no longer required for the purpose for which it was collected or processed or to comply with a legal obligation, we destroy it in a secure manner.

For data related to orders on the online store, they are kept for a period of 5 years from the last contact, except for data related to the establishment of invoices which are kept for 10 years
For data related to subscriptions to one of the COMPASS services, they are kept for a period of 5 years from the last contact
For traffic data collected at the back office level, a period of 12 months
For log data, a duration of 12 months
For data collected via contact forms, a period of 6 months
In case of inactivity for the data collected in the framework of the subscription to the newsletters (TOP 5), 3 years as from the last follow-up

Whers is your personal data stored?

Your personal data is stored only in our databases and these databases are stored on dedicated servers in the European Union (E.U)

With whom do we share Personal Data?

Clean Horizon does not share your Personal Data with any third party, except with your client administrator and or company representative if you are a subscriber to one of the COMPASS online services or if you are registered for one of our training courses available on the online store. We will not disclose to third parties the information and Personal Data you provide to us. This information and Personal Data is used exclusively by our internal services and will not be transferred or sold to third parties.

Do we transfer you personal data outside the European Economic Area?

We do not transfer any Personal Data of our Users outside the European Union.

What are your rights to your data?

The owner of the data has the following rights:

Right to information - which means you need to know whether your personal data is being processed, what data is being collected, where it comes from and why and by whom it is being processed.
Right of access - this means that you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your collected personal data.
Right of rectification - this means that you have the right to request the rectification or deletion of your personal data that are inaccurate or incomplete.
Right to erasure (or right to be forgotten) - which means that under certain circumstances you can request that your personal data be deleted from our records.
Right to restrict processing - meaning that under certain conditions, you have the right to restrict the processing of your personal data.
Right to object to processing - this means in some cases that you have the right to object to the processing of your personal data, for example in the case of direct marketing.
Right to object to automated processing - this means that you have the right to object to automated processing, including profiling; and not to be subject to a decision based solely on automated processing. This right, you can exercise whenever there is a result of profiling that produces legal effects concerning or significantly affecting you.
Right to data portability - you have the right to obtain your personal data in a machine-readable format or, if feasible, as a direct transfer from one processor to another.
Right to withdraw your consent - you have the right to withdraw any consent given for the processing of your personal data.

Fore more information on your rights, please visit the CNIL website.

If you have an account, subscribe to newsletters or have submitted a contact request on the site, you can request a file request a file containing all the personal data we hold about you, including that which you have provided.

Clean Horizon undertakes to respond to your request within a reasonable period of time, which may not exceed 1 month from the receipt of your request.

How do we protect your data?

We maintain security procedures and take reasonable technical and organizational measures to protect your personal data from accidental or unlawful destruction, loss, disclosure or unauthorized use.

We will ensure that access to and use of your personal information is limited to authorized persons who reasonably need to know that information to provide our services (e.g., billing or customer service) and for the proper performance of our business, and who are bound by confidentiality obligations. The computers and servers used to store personally identifiable information are kept in a secure environment. We also use SSL (secure sockets layer) encryption, a feature that encrypts all information exchanged.

To help ensure the security of your Personal Information, please be sure to choose a password that is sufficiently protective when you reset your password on our COMPASS Platform. You are solely responsible for maintaining the confidentiality of your password and its use in accordance with the Terms of Use of the Site to which you have agreed.

How do we respect your privacy in our marketing activities?

Clean Horizon uses a variety of communication methods and tools to market its services. We send prospecting emails to people who consent or when we have a legitimate interest to do so and when applicable law allows us to do so. You may opt-out of receiving marketing emails from us by clicking on the "Unsubscribe" or "Opt-out" link at the end of the relevant email or by contacting us at dpo@cleanhorizon.com.

Cookie management policy

When you first connect to the Clean Horizon website, a banner briefly presenting information about the deposit of cookies and similar technologies appears at the bottom of your screen. This banner warns you that by continuing your navigation on the CLEAN HORIZON website (by loading a new page or by clicking on various elements of the site for example), you accept the deposit of cookies on your terminal. It tells you, including all the cookies on our website, their purpose and gives you the procedure to set the cookies you want.

General information about cookies ?

Clean Horizon as editor of this website can proceed to the implantation of a cookie on the hard disk of your terminal (computer, tablet, mobile, etc.) only with your consent in order to guarantee an optimal and fluid navigation on our website. Cookies" are small delimited text files that allow us to recognize your computer, tablet or mobile in order to personalize the services we offer.
The information collected via cookies does not in any way identify you by name. It is used exclusively for our own purposes to improve the interactivity and performance of our website and to send you content tailored to your interests. None of this information is disclosed to third parties unless Clean Horizon obtains your consent or where disclosure is required by law, court order, or administrative or judicial authority.
To further clarify the information that cookies identify, you will find below a list of the different types of cookies that may be used on the site, their name, their purpose and their retention period.

How do you set your cookie preferences?

You can accept, choose or refuse the deposit of cookies at any time. When you first connect to the Clean Horizon website, you are also deemed to have given your consent to the deposit of cookies by clicking on the "OK" icon on the right of the banner at the bottom of your screen.
Depending on the type of cookie concerned, the collection of your consent to the deposit and reading of cookies on your terminal may be imperative.

What types of cookies do we use?

The types of cookies that may be used on the Clean Horizon website can generally be classified into one of the following categories: strictly necessary (consent-exempt cookies); requiring consent (targeting); and analytical.

Cookies exempt from consent

Following the recommendations of the National Commission for Computers and Liberty (CNIL), some cookies are exempt from the collection of prior consent because they are strictly necessary for the operation of the site or have the sole purpose of authorizing or facilitating electronic communication.

Name of the cookie	Supplier	Objective	Duration
apisid	Google	This cookie is used to collect information to measure the number and behavior of users of Google Maps.	2 years
phpsessid	Cleanhorizon	This cookie establishes communication between the web server and the browser and temporarily stores information about your session. It ensures, for example, that you do not have to fill out a form again completely if you reload the page or make an error.	Session
chcookie	Cleanhorizon	Apache tracking cookie embedded in the Server level.	Session

These cookies are entirely subject to this policy since they are issued and managed by Clean Horizon.

Cookies requiring consent prior to the collection of your data

This requirement concerns cookies issued by third parties and which are said to be "persistent" since they remain on your terminal until their deletion or expiration date. These cookies are issued by third parties, their uses and deposits are subject to their own privacy policies which you can find the links below. This family of cookies includes advertising cookies and social network sharing cookies (including Twitter, LinkedIn and User.com). Social network sharing cookies are issued and managed by the publisher of the relevant social network.

· LinkedIn, you can find, the cookie policy by clicking here

· Twitter, you can find the options for controlling or restricting the use of cookies and the cookie policy here

· User.com, you can find the cookie policy by clicking here

With your consent, cookies allow you to easily share some of the content published on the Clean Horizon website, including via an application sharing "button" by the social network in question.

Analytical cookies

These are cookies that allow us to know the use and performance of our site, to establish statistics, volumes of attendance and use of the various elements that make up our sites (sections and content visited, path), allowing us to improve the interest and ergonomics of our services (for example, the pages most often consulted, searches by Internet users in our search engine...).

Below is a list of the cookies on our site. Information about the cookies we use may be updated from time to time, so please check this cookie policy regularly for any changes.

Name of the cookie	Supplier	Objective	Duration
SIDCC	Google	Preferences and information	1 year old
__Secure-3PSID, 3PAPISID, 1P_JAR	Google	Create a profile of website visitors' interests to display relevant and personalized ads through retargeting.	2 years
_grecaptcha	Google	This cookie is used to distinguish humans from robots.	1 year old
XSRF-TOKEN	Laravel	This is a security cookie for the detection of bad requests sent to the server.	1 day/session
Cleanhorizon_session	Framework travel	This cookie is used to recognize users connected to the backoffice of the site	1 year old
Search_samesite	Google	This cookie is used to prevent the browser from sending cross-site cookies.	2 years
Axeptio_authorized_vendors	Axeptio, twitter, LinkedIn and User.com	This is a consent cookie based on how you arrived on the site (LinkedIn, twitter, user.com or any)	1 year old
_ueuuid	User.com	Tracks anonymous visits; it is assigned to anyone who lands on the website	12 months
SSID, HSID	Google	This is a connection identification, it includes the preferred language, type of device used, the number of search results to display on the page.	2 years
Axeptio_cookies	Axeptio	Allows you to manage the user's consent to the different categories of cookies.	1 year old

Accepting or refusing cookies: What are the steps?

You have different tools for setting cookies

Most Internet browsers are configured by default so that the deposit of cookies is authorized. Your browser offers you the possibility to modify the standard settings so that all cookies are systematically rejected or that only some of the cookies are accepted or rejected depending on the sender.

Accepting or refusing cookies: What are the steps?

Your web browser settings

You can choose to disable these cookies at any time. Your browser can also be set to notify you when cookies are placed on your computer and to ask you to accept or decline them. You can accept or decline cookies on a case-by-case basis or decline them once and for all.

If your browser is set to reject all cookies, you may not be able to take advantage of essential features of our site. In order to manage cookies in a way that best suits your needs, we invite you to configure your browser according to the purpose of the cookies as mentioned above.

The configuration of each browser is different. It is described in your browser's help menu, which will tell you how to change your cookie preferences. You can refer to the page of the editor of your browser to know the parameter setting relating to the management of the cookies.

Depending on the browser, there are several options available, such as deleting existing cookies, blocking certain cookies, deleting cookies when you close your browser, or generally refusing to allow the site to track you. You can also apply exceptions to a general rule for a given site.

For more information on these settings, we suggest you visit the links below or click on the Help tab of your browser.

if your browser (or your browser version) is not listed, you can go directly to its publisher's website for more information.

However, we would like to draw your attention to the fact that when you object to the installation or use of a cookie, a refusal cookie is installed on your terminal equipment. If you delete this refusal cookie, it will no longer be possible to identify you as having refused the use of cookies. Clean Horizon does not assume any responsibility for the consequences of the breakdown of your navigation conditions which occur because of your choice to refuse, remove or block the cookies necessary for the functioning of the site. These consequences do not constitute any damage and you cannot claim any compensation for this fact. Your browser also allows you to delete existing cookies on your terminal or to alert you when new cookies may be stored on your terminal. These settings do not affect your browsing experience but you lose the benefit of the cookie.

For more information on cookie management tools, you can visit the CNIL website by clicking here.

Unless express consent is required by the laws of your country for the protection of personal data, by using this medium (as defined above), you consent to our collection and use of your personal data as described in this data protection policy.

How to contact us or exercise your rights?

To exercise your rights or if you have any questions or comments about these principles or our personal data protection practices, or any questions about a possible violation of these principles, our practices or any applicable legal provisions regarding the protection of personal data, please contact our CLEAN HORIZON Data Protection Officer (DPO) by e-mail at dpo@cleanhorizon.com or by mail at the following address CLEAN HORIZON, 12 rue de la Chaussée d'Antin 75009 Paris, France.

Good visit on cleanhorizon.com

DATA PROTECTION AND COOKIE MANAGEMENT POLICY

Website owner

CLEAN HORIZON CONSULTING