This data protection policy (hereinafter referred to as the "Policy") sets out the manner in which user data is processed within the framework of this NaTran R&I website by NaTran (hereinafter referred to as the "Site").
NaTran, a public limited company registered under number 440 117 620 R.C.S. Nanterre, France and whose registered office is located at 6 rue Raoul Nordling, 92270 Bois-Colombes, France, hereinafter "NaTran" or "We", is responsible for processing the personal data of users of the Site (the "Data Controller").
Users of this site may communicate personal data concerning them to NaTran, the site's publisher, by using the various collection media, tools and services made available to them on the site, hereinafter referred to as "you" or "your Personal Data".
The Personal Data collected may be subject to processing, automated or otherwise, in accordance with the provisions relating to the protection of personal data, including the General Data Protection Regulation "RGPD" applicable since May 25, 2018 and under the conditions attached to each collection medium and this Policy.
1. WHAT CATEGORIES OF DATA DO WE COLLECT?
By "Personal Data", we mean any information about an individual from which that person can be identified. This does not include data for which the identity has been removed (anonymous data).
NaTran R&I collects the following categories of Personal Data for the purposes described below in Our Policy:
a) your identity ;
b) your Faro ID ;
c) information filled in on forms, questionnaires and requests for information;
d) your image or voice if you use NaTran tools capable of recording you and you consent to publication on the site;
e) information that you communicate publicly, on our social networks or websites, for example to give your opinion;
f) when you use our websites: information about your browser, your browsing behaviour, the type of terminal you use (smartphone, computer, tablet...), your terminal's operating system, your Internet service provider, your terminal's IP address, your terminal's geolocation;
g) when you use our mobile applications: We may collect your GPS position, with your consent if required, as well as the frequency with which you use the application. We also collect information about the browser you use and your browsing behavior.
2. WHAT DO WE USE YOUR DATA FOR?
Your Personal Data is processed for the purposes described below:
Data category Purposes Legal basis
Your identity
Your browsing data (preferences, terminal type, operating system, internet service provider, browsing behavior, IP address, etc.) Improvement of the user experience (better understanding of your use of the services and your interests).
Improvement of our sites, applications and services.
Personalization of your experience and adaptation of our services. Legitimate interest of NaTran.
Your identity
Data provided by you on forms available on NaTran sites and applications
Your image and/or voice
Your publicly communicated information Relations with users and more specifically processing requests, answering questions, managing complaints, transmitting information, etc.
Newsletter registration and management. Fulfilment of the contract concluded with NaTran.
Your connection data (Faro ID)
Your browsing data (preferences, type of terminal, operating system, Internet service provider, browsing behaviour, IP address, etc.) Fight against the risks of fraud, theft or any reprehensible act.
And more generally protection of the security of NaTran, its employees, its sites and applications. Legitimate interests of NaTran
Your browsing data (preferences, type of terminal, operating system, Internet service provider, browsing behavior, IP address, etc.)
Your location data Carrying out analyses on the e-reputation of NaTran or its services.
Measuring the effectiveness of online and offline campaigns or events.
Preserving NaTran's image and improving marketing campaigns. Legitimate interest of NaTran
Consent (occasionally).
3. WITH WHOM DO WE SHARE YOUR DATA?
We only communicate or share your Personal Data in the following cases:
a) with subcontractors acting on our behalf: for example, technical service providers in charge of sending emails for Us, or hosting our website. We may also share information about you with suppliers who help us operate our websites;
b) with certain business partners, subject to your consent: for example, We will share your Personal Data with third parties who organize an event jointly with Us;
c) with a third party in connection with a corporate restructuring or reorganization, including dissolution, liquidation or any transfer including assignment or merger;
d) with NaTran employees authorized by virtue of their functions and bound by an obligation of confidentiality;
d) when We are legally required to do so to comply with applicable law, to respond to a court order, or more generally to satisfy any request from an authorized authority.
Third parties with whom We share your Personal Data are limited (by law and by contract) in their ability to use your Personal Data for the purposes We have identified. We will make every effort to ensure that third parties with whom We share your Personal Data are subject to confidentiality and security obligations that comply with this Policy and the GDPR. We only allow them to process your Personal Data for specific purposes and in accordance with our instructions.
Except as expressly stated above, We will never share, sell or rent your Personal Data to a third party without notifying you and/or obtaining your consent. If you have given Us your consent for Us to use your personal data in a particular way, but subsequently change your mind, you should contact Us and We will stop doing so.
4. COOKIES
When you visit our Site, information relating to your browsing may be recorded in “cookie” files installed on your terminal (computer, tablet, smartphone, etc.), subject to the choices you make concerning cookies, which you may modify at any time.
The information below will help you better understand how cookies work and how to use the current tools to set them.
What is a cookie?
A cookie is a small text, image or software file containing information that is stored on the hard disk of your terminal (e.g. computer, tablet, smartphone, or any device used for browsing the Internet) when you visit a website using your browser. It is transmitted by a website server to your browser. The cookie file records the pages you visit, the type of browser you use and your IP address, and enables the sender to identify the terminal in which it is stored, for the duration of the validity or storage of the cookie concerned.
Only the sender of a cookie can read or modify the information contained in it.
Why do we use cookies?
We use 3 categories of cookies, the purposes of which are described below.
Certain technical cookies (session cookies in particular) are essential for the proper operation of the Site.
When prior consent is required for the use of cookies, the period of validity of the consent is 6 months. At the end of this period, we will ask for your consent again. The cookies that We place as operators of our Site and/or our application are called "internal cookies". Cookies that third parties have entrusted to Us on our Site and/or our application are called "third-party cookies". Third-party cookies enable us to provide third-party features or functionalities on or via a website (e.g. advertising, interactive and analytical content). The people who create these third-party cookies may collect some of your personal information and recognize your computer both when you visit the website in question and when you visit other websites.
A cookie is retained for 13 months. However, the information collected through these cookies is kept by us for a maximum of 25 months, in accordance with French and European regulations.
5. Technical cookies
Technical cookies are strictly necessary for the operation of the Site. They enable access to reserved and personal areas of our Site, thanks to personal identifiers (session identifier cookie), to implement security measures (for example, when you are asked to connect again to a content or service after a certain period of time), to enable or facilitate communication for the provision of a service by electronic means expressly requested by the Internet user. These cookies are deleted as soon as you close your browsing session.
These cookies are issued and stored by NaTran. They have a very short lifespan, for most of them, the time of the session, and a maximum of 13 months.
List of functional cookies used on the NaTran R&I website.
Cookie Cookie description Retention period
AWSALB Used by Amazon to optimize the user experience 7 days
viewed_cookie_policy Stores the user's consent to their choice regarding cookies. 11 months
cookielawinfo-checkbox-necessary Stores user consent for cookies in "Necessary" category 11 months
cookielawinfo-checkbox-non-necessary Stores user consent for cookies in "Non-Necessary" category 11 months
cookielawinfo-checkbox-advertisement Stores user consent for cookies in the "Advertising" category 12 months
cookielawinfo-checkbox-analytics Stores user consent for cookies in the "Analytics" category 12 months
cookielawinfo-checkbox-performance This cookie is used to track which cookies the user has approved for this site. 12 months
CONSENT Stores user consent across all cookie categories 12 months
apbct_ Used by CleanTalk and acts as an anti-spam and firewall solution for this site. Session
ct_pointer_data Acts as a complete anti-spam and firewall solution for this site. Session
ct_timezone Stores the time of the visit. Session
2. Audience measurement cookies - statistics
These cookies collect information on how visitors use a website. For example, the number of visits, the most frequently visited pages, etc. These cookies enable us to compile statistics for analyzing visitor numbers, and to improve the content of our site according to the success of a particular page with our visitors.
The statistics tool used by NaTran generates a cookie with a unique identifier, the duration of which is limited to 6 months. We collect your IP address to identify the city from which you are connecting. The last two bytes are immediately anonymized. The data collected will not be passed on to third parties or used for any other purpose.
3. Sharing cookies (social networks)
Our Site contains sharing buttons ("plug-ins") to Facebook, Twitter, Instagram, Linkedin, Youtube and others that allow you to share content from our Site with others. When you use these sharing buttons, your web browser will establish a connection with the servers of the social networks concerned and a third-party cookie will be installed after your consent has been obtained. If you are connected to the social network while browsing our Site, the sharing buttons allow you to link the content you consult to your user account.
In this context, the purposes and scope of the use of your Personal Data, additional processing and your rights will be subject to the privacy policies of the social network providers and placed under their full and sole responsibility.
List of non-functional cookies used on the NaTran R&I website.
Cookie Cookie description Retention period
test_cookie Test whether the browser supports cookies 11 months
IDE Stores information about how the user uses the website and any advertising before visiting the website. 12 months and 24 days
_ga Used by Google Analytics to track the user's use of the site. Anonymous. 2 months
_gid Used by Google Analytics to store information about how visitors use a website. Anonymous. 1 day
GPS Defined by Youtube and records a unique identifier for user gps tracking. 30 minutes
vuid Used by Vimeo to collect tracking information. 13 months
YSC Defined by Youtube and used to track views of embedded videos. Session
VISITOR_INFO1_LIVE Defined by Youtube and used to track information about embedded YouTube videos on a website. 2 months and 27 days
How do I manage cookies?
You can personalize your cookie choices directly on our website using the banner at the foot of the page. There are several other ways to manage cookies on your side, such as setting your browser parameters directly, or installing a cookie-blocking tool. Any settings you make may affect your browsing on the Site.
Your choices expressed online directly from our Site
From our Site, you can configure your choices concerning the cookies that We place on your terminal, by directly using the cookie consent platform.
On your first visit to our Site, you will be asked to consent to the use of Your Personal Data by cookies via an information banner which will be displayed visibly at the bottom of the page.
Using the "Accept all" and "Reject all" buttons, you can accept or reject all cookies placed on your computer or device (cookies related to targeted advertising operations, certain audience measurement cookies, social network cookies generated in particular by their sharing buttons when they collect personal data). Nevertheless, a third "Settings" button on this banner will allow you to obtain details of the categories of cookies used, and thus to choose whether or not to consent to each objective.
To exercise your rights or for any general questions about the processing of your Personal Data under this system, you may contact the Data Privacy Manager appointed by NaTran, at the following postal address: NaTran, 6 rue Raoul Nordling, 92270 Bois-Colombes or by e-mail: protectiondesdonnees@natrangroupe.com.
5. TRANSFERT DE VOS DONNÉES HORS DE L’UNION EUROPEENNE
The Personal Data we have collected about you may be transferred to and processed in a country or region where NaTran operates, outside the European Union.
Where We transfer your Personal Data to a country/region outside the European Union, We ensure an adequate level of protection for the information transferred to these third countries/regions by transferring your Personal Data to countries/regions that have been the subject of an adequacy decision by the European Commission within the meaning of Article 45 of the RGPD, by entering into data transfer agreements with these recipients based on the standard contractual clauses as validated by the European Commission or any other valid transfer mechanism that may be available (BCR for example).
6. DURÉE DE CONSERVATION
Your Personal Data will only be retained, in a form that allows you to be identified, for as long as is reasonably necessary for the purposes described above, or for as long as is permitted by law.
In determining the appropriate retention period for Personal Data, We take into account the amount, nature and sensitivity of the Personal Data, the potential risk of harm resulting from the unauthorized use or disclosure of your Personal Data, the purposes for which We process your Personal Data and the possibility of achieving those purposes by other means, as well as applicable legal requirements.
We retain Personal Data:
- claims, questions, complaints: 3 years following a claim, question or complaint that has been closed;
- contact form: 3 years from the date of your request;
- newsletter subscription: as long as the person concerned does not unsubscribe;
- browsing the Site: see the durations associated with cookies.
Once these deadlines have passed, Personal Data is either deleted or kept after being anonymized, notably for statistical purposes. They may be kept for pre-litigation and litigation purposes. Please note that deletion or anonymization are irreversible operations and that NaTran is no longer able to restore them.
7. YOUR RIGHTS
As a data subject, you have various rights. These rights are not absolute and each of these rights is subject to certain conditions in accordance with the GDPR and applicable national laws.
Right of access
You may request access to the data about you that We hold. In this case, we will provide you with the information required by law on the purposes of the processing, the categories of data processed, the categories of recipients, the data retention period, etc.
Right to portability
You may also obtain a copy of any information about you that We hold, in a compatible and structured format enabling you to exercise your right to data portability, for processing based on your consent or the performance of a contract between NaTran and you or whose processing is carried out by automated means.
Right of rectification
You may request that we take steps to correct your Personal Data if it is inaccurate or incomplete (for example, if We have the wrong name or address).
Right to erasure
You may request the deletion of your Personal Data if (i) they are no longer necessary for the intended purpose, (ii) you have withdrawn your consent even though the processing in question was based on that consent, (iii) you have objected to the processing (iv) the data processing is unlawful, (v) the information must be erased in application of legal obligations applicable to NaTran.
Right to limit processing
You may request the limitation of processing. (i) if you dispute the accuracy of your personal information, which will allow NaTran to verify this accuracy, (ii) if you wish to limit the processing of your information rather than have it erased despite the fact that the processing is unlawful (iii) if you want NaTran to keep your information because you need it to establish, exercise or defend your legal rights (iv) the time necessary for NaTran to examine the validity of your opposition request.
Right to withdraw consent
Where the processing of your Personal Data is based on consent, you may withdraw such consent at any time, which will not affect the legitimacy of the processing operations carried out prior to the withdrawal of your consent.
Right to object
Where the processing we carry out is based on our legitimate interests, you may object to such processing if your interests or fundamental freedoms are found to override our legitimate interests.
Right to provide instructions on the use of your Personal Data after your death
You have the right to provide Us with instructions on the management (for example, retention, erasure and disclosure) of your Personal Data after your death. You may modify or revoke your instructions at any time.
Making a complaint about your Personal Data
If you have any questions about how We process your Personal Data or if you wish to exercise any of your rights, please contact our Data Privacy Manager at protectiondesdonnees@natrangroupe.com.
In principle, exercising your right of access (or any other right) will not generate any costs. Occasionally, if your request is manifestly unfounded or excessive (in particular because of its repetitive nature), We may require payment of a reasonable fee and/or refuse to accede to your request.
We may need to ask you for specific information to help Us confirm your identity and guarantee your right to access this information (or to exercise your other rights). This is an appropriate security measure to ensure that Personal Data is not disclosed to anyone who is not entitled to receive it.
You also have the right to lodge a complaint with the relevant supervisory authority, which is the Commission Nationale de l'Informatique et des Libertés ("CNIL") in France here or by writing by post to: CNIL - Service des Plaintes - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.
8. PROTECTION OF YOUR DATA
We will provide an adequate level of protection for your data and will ensure that appropriate technical and organizational security measures (including awareness and training of personnel involved in processing operations) are in place to protect your Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other forms of unlawful processing.
However, as the Internet is not completely secure, We cannot guarantee that your Personal Data stored or sent will be completely secure. We encourage you to exercise caution when using the Internet to access our sites or applications.
9. THIRD-PARTY SITES
Links may be made to third-party sites or services that We do not control and that are governed by their own privacy policies. This Policy does not apply to these third-party sites. We invite you to consult the privacy policies of the third-party sites you visit to find out how they handle your personal data.
10. MODIFICATION OF THE POLICY
Our Policy may be amended from time to time to reflect changes in the way We process information about you. We will post an updated version of this Policy on the Site.
11. CONTACT US
If you would like Us to update the information We have about you or your preferences, or if you have any questions regarding the protection of Personal Data, please contact Us by e-mail at protectiondesdonnees@natrangroupe.com.
