Table of Contents

Privacy Policy

ARTICLE 1: Preamble

This privacy policy applies to the site: www.avecpanache.co.

The purpose of this privacy policy is to explain to site users:

How their personal data is collected and processed.

Personal data should be considered as any data capable of identifying a user. This includes, in particular, first and last name, age, postal address, email address, the user's location, or their IP address;

What the users' rights are regarding this data;
Who is responsible for the processing of the personal data collected and processed;
To whom this data is transmitted;
If applicable, the site's policy regarding "cookie" files.

This privacy policy supplements the legal notice.

ARTICLE 2: General principles for data collection and processing

In accordance with the provisions of Article 5 of European Regulation 2016/679, the collection and processing of site user data respect the following principles:

- Lawfulness, fairness, and transparency: data may only be collected and processed with the consent of the user who owns the data.

- Whenever personal data is collected, the user will be informed that their data is being collected and the reasons why;
- Limited purposes: data collection and processing are carried out to meet one or more objectives determined in these general terms of use;
- Data minimization: only data necessary for the proper execution of the site's objectives is collected;
- Limited data retention: data is kept for a limited period, of which the user is informed. When this information cannot be provided, the user is informed of the criteria used to determine the retention period;
- Integrity and confidentiality of collected and processed data: the data controller undertakes to guarantee the integrity and confidentiality of the data collected.

To be lawful, and in accordance with the requirements of Article 6 of European Regulation 2016/679, the collection and processing of personal data may only occur if they meet at least one of the following conditions:
- The user has expressly consented to the processing;
- The processing is necessary for the proper performance of a contract;
- The processing is required by a legal obligation;
- The processing is necessary to protect the vital interests of the data subject or another natural person;
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority;
- The collection and processing of personal data are necessary for the legitimate and private interests pursued by the data controller or by a third party.

ARTICLE 3: Personal data collected and processed during site navigation

A. DATA COLLECTED, PROCESSED, AND COLLECTION METHODS

The personal data collected on the PANACHE website is as follows:

- First name and email address.

This data is collected when the user performs one of the following operations on the site:
- Registering for a Training Course
- Subscribing to the Newsletter

- Downloading a Resource

Furthermore, when a payment is made on the site, proof of the transaction, including the order form and invoice, will be kept in the site publisher's computer systems.

The data controller will store all collected data in the site's computer systems under reasonable security conditions for a period of: 5 years.

The collection and processing of data serve the following purposes:
Filtering content

B. DATA SHARING WITH THIRD PARTIES

Personal data collected by the site is not shared with any third parties and is processed only by the site publisher.

ARTICLE 4: Data controller and data protection officer

A. THE DATA CONTROLLER
The personal data controller is: JULIEN DE SOUSA.

They can be contacted as follows: julien@avecpanache.co


The data controller is responsible for determining the purposes and means used for the processing of personal data.

B. DATA CONTROLLER OBLIGATIONS
The data controller commits to protecting the personal data collected, not to share it with third parties without informing the user, and to respect the purposes for which the data was collected.

The site uses an SSL certificate to ensure that information and data transfers occurring through the site are secure.

An SSL (Secure Socket Layer) certificate is used to secure data exchanged between the user and the website.


Additionally, the data controller undertakes to notify the user in the event of data rectification or deletion, unless doing so would involve disproportionate formalities, costs, or efforts.

In the event that the integrity, confidentiality, or security of the user's personal data is compromised, the data controller undertakes to inform the user by any means necessary.

C. THE DATA PROTECTION OFFICER
Furthermore, the user is informed that the following person has been appointed as Data Protection Officer: JULIEN DE SOUSA.


The role of the Data Protection Officer is to ensure the proper implementation of national and supranational provisions relating to the collection and processing of personal data. They are also known as the DPO (Data Protection Officer).

The Data Protection Officer can be contacted as follows: julien@avecpanache.co

ARTICLE 5: User Rights

In accordance with regulations concerning the processing of personal data, users possess the rights listed below.


To ensure the data controller can fulfill their request, the user must provide their first name, last name, and email address.

The data controller is required to respond to the user within a maximum of 30 (thirty) days.

A. OVERVIEW OF USER RIGHTS REGARDING DATA COLLECTION AND PROCESSING

a. Right of access, rectification, and erasure
Users may view, update, modify, or request the deletion of their data by following the procedure below:
An email must be sent to the data controller so that they can delete all information concerning the user.

b. Right to data portability
Users have the right to request the portability of their personal data held by the site to another site by following the procedure below:
Users must submit a portability request by sending an email to the address provided above.

c. Right to restrict and object to data processing
Users have the right to request the restriction of or object to the processing of their data by the site. The site cannot refuse this request unless it can demonstrate compelling legitimate grounds that override the user's interests, rights, and freedoms.

To request the limitation of the processing of their data or to object to the processing of their data, the user must follow the following procedure:
The user must send an email indicating the limitation of the processing of their data or expressing an objection to their processing to the email address provided above.

d. Right not to be subject to a decision based exclusively on automated processing
In accordance with the provisions of Regulation 2016/679, the user has the right not to be subject to a decision based exclusively on automated processing if the decision produces legal effects concerning them or similarly significantly affects them.

e. Right to determine the fate of data after death
Users are reminded that they may organize the future of their collected and processed data in the event of their death, in accordance with Law No. 2016-1321 of October 7, 2016.

f. Right to lodge a complaint with the competent supervisory authority
If the data controller decides not to respond to the user's request and the user wishes to contest this decision, or if they believe that any of the rights listed above have been infringed, they are entitled to contact the CNIL (Commission Nationale de l’Informatique et des Libertés, https://www.cnil.fr) or any competent court.

B. PERSONAL DATA OF MINORS
In accordance with the provisions of Article 8 of European Regulation 2016/679 and the Data Protection Act, only minors aged 15 or older may consent to the processing of their personal data.
If the user is a minor under the age of 15, the consent of a legal guardian will be required for personal data to be collected and processed.
The site publisher reserves the right to verify by any means that the user is over 15 years of age or has obtained the consent of a legal guardian before browsing the site.

ARTICLE 6: Use of cookies

The site may use cookie technology.
A cookie is a small file (less than 4 KB) stored by the site on the user's hard drive, containing information related to the user's browsing habits.

These files allow the site to process statistics and traffic information, facilitate navigation, and improve the service for the user's convenience.
For the use of cookies involving the storage and analysis of personal data, the user's consent is required.

This user consent is considered valid for a maximum period of 13 (thirteen) months. At the end of this period, the site will again request the user's authorization to store cookies on their hard drive.

a. User objection to the use of cookies by the site
Users are informed that they may object to the storage of these cookies by configuring their browser settings.

For information, users can find the steps to configure their browser to block cookies at the following addresses:
- Chrome: https://support.google.com/accounts/answer/61416?hl=en
- Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Safari: http://www.apple.com/legal/privacy/en-ww/
- Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

- Opera: http://www.opera.com/help/tutorials/security/cookies/

If the user decides to disable cookies, they may continue browsing the site. However, any site malfunction caused by this action cannot be attributed to the site publisher.

b. Description of cookies used by the site
The site publisher would like to inform the user that the following cookies are used during their visit:

________
By browsing this site, the user is informed that third-party cookies may be stored.

These third parties specifically include:
- MailerLite

- Webflow
- Typeform
- Google Analytics

- Google Tag Manager

- Clarity (Microsoft)

- Hotjar

Furthermore, the site includes social media buttons, allowing users to share their activity on the site. Cookies from these social networks may therefore be stored on the user's computer when these features are used.

Users are advised that these sites have their own privacy policies and terms of use that may differ from those of this site. The site publisher encourages users to review the privacy policies and terms of use of these sites.

ARTICLE 7: Terms for modifying the privacy policy


The site publisher reserves the right to modify this policy to ensure compliance with current laws.
Consequently, users are encouraged to check this privacy policy regularly to stay informed of any updates.
Please be advised that the last update to this privacy policy was made on: 03/02/2022.

ARTICLE 8: User acceptance of the privacy policy

By browsing this site, the user acknowledges that they have read and understood this privacy policy and accepts its terms, particularly regarding the collection and processing of their personal data, as well as the use of cookies.