PRIVACY POLICY

This privacy policy (hereinafter referred to as the "Privacy Policy) defines the legal framework for collection, use and processing by CYRIA (hereinafter referred to as "CYRIA"). CYRIA ("CYRIA") personal data concerning users browsing and/or making use of the services offered by CYRIA (hereinafter referred to as the "users"). Users ") accessible on the "cyria.net" web platform designed, developed and operated by CYRIA (hereinafter referred to as the " Platform ").

Under the terms of the Privacy Policy, the person responsible for processing personal data is CYRIA, a simplified joint stock company, whose registered office is located at Mas de Sauveterre, 165 chemin de l'Aubère, 13100 Aix-en-Provence (France).registered with the Registre du Commerce et des Sociétés d'Aix-en-Provence under number 494 306 053.

As data controller, CYRIA retains full control over personal data and determines the object, nature, purposes, means and duration of the processing of Users' personal data (hereinafter referred to as the " Data Personal ").

The Personal Data collected in the context of the Privacy Policy is mandatory and necessary for the processing and provision of the services offered by CYRIA via the Platform (hereinafter referred to as the "Services"). "Services). Failure to provide this information will prevent the proper functioning and supply of the Services offered.

CYRIA undertakes to comply with the regulations applicable to the protection of personal data and in particular the obligations arising from European Regulation No. 2016/679 on the protection of personal data (hereinafter referred to as the " RGPD ").

CYRIA collects Personal Data only in accordance with the terms of this Privacy Policy and any reasonable legal instructions given by the User at any time.

ARTICLE 1: INFORMATION COLLECTED

1.1 Throughout the use of the Platform, CYRIA may collect Personal Data concerning Users, i.e. any information directly or indirectly identifying the User.

When using the Platform for the first time, the User expressly consents to the processing of his/her Personal Data within the limits of the processing strictly necessary for the proper functioning of the Platform and Services.

1.2 Personal Data relating to Users may be collected directly when the User communicates them to CYRIA by creating an account, filling in forms, requesting contact or reporting illicit content.

1.3 CYRIA (including its technical service providers) may also indirectly and automatically collect :

Data relating to the User's activity;
Data relating to the User's browsing, in particular the anonymized IP address, the browser used, the browsing time, the operating system used, the language and the pages viewed;
Data relating to the use of the Platform by the User, in particular traffic data, the number of notifications, the number of visits, the number of data updates, the number of launches of the Platform and any other data or communication resources used by the User when accessing the Platform.

ARTICLE 2: USE OF PERSONAL DATA COLLECTED (PURPOSES OF PROCESSING)

CYRIA uses, stores and processes Personal Data for the following purposes and on the following legal grounds:

Purpose	Legal basis for processing
Access to and use of the Platform by the User	The processing is necessary for the performance of the contract concluded between the User and CYRIA.
Provision of Services on the Platform	The processing is necessary for the performance of the contract concluded between the User and CYRIA.
Answering users' questions/complaints - Assistance	The processing is necessary for the performance of the contract concluded between the User and CYRIA.
Management of requests for access, portability, deletion, rectification and opposition rights	The processing is necessary for the performance of the contract concluded between the User and CYRIA.
Developing and enhancing the platform, creating an environment of trust	The processing is necessary for the purposes of CYRIA's legitimate interests.
Sales prospecting	Processing is carried out on the basis of the User's consent.
Audience measurement, Sales statistics	The processing is necessary for the purposes of CYRIA's legitimate interests.

CYRIA also grants itself the right to review, scan or analyze Personal Data, including communications exchanged between CYRIA and Users via the Platform, to comply with its legal obligations and in particular for purposes of fraud prevention, risk assessment, regulatory compliance and investigation.

ARTICLE 3: STORAGE OF PERSONAL DATA

Personal Data is retained only as long as necessary for the fulfillment of the purpose for which CYRIA holds such data, in order to meet the needs of Users or to fulfill its legal obligations.

CYRIA uses the following criteria to determine the length of time it keeps personal data:

Type of treatment	Shelf life
Access to and use of the Platform by the User - Provision of Services	Retention until the end of a period of inactivity and within the limits of legal requirements
Commercial prospecting	Retention up to 3 years after collection or last contact with the User
User request (Contact, assistance, exercising rights)	Retention for as long as necessary to process the request

At the end of the aforementioned periods or at the latest six (6) months from the end of the use of the Services by the User, the Personal Data will be destroyed or CYRIA will proceed with their anonymization.

However, CYRIA may keep certain Personal Data collected on separate storage spaces in order to justify, where applicable, the full performance of its contractual or legal obligations. Data stored in this way will be limited to what is strictly necessary.

ARTICLE 4: SHARING AND DIVULGING PERSONAL DATA

4.1 CYRIA may disclose Personal Data to administrative and judicial authorities, or to authorized third parties, if required or permitted by law, or if such disclosure is reasonably deemed necessary: (i) to comply with CYRIA's legal obligations, (ii) to comply with legal process and to pursue claims against CYRIA, (iii) to respond to verified requests in connection with a judicial investigation or alleged or suspected illegal activity or any other activity that may expose CYRIA to legal liability.

4.2 Subject to the User's authorization, CYRIA may subcontract all or part of the execution of the Services in compliance with the legal provisions in force.

Within this framework, CYRIA will not transfer Personal Data to third parties established outside the European Union that do not offer an adequate level of protection with regard to the legal requirements for the protection of Personal Data.

Any subcontractor will be authorized to process, on behalf of CYRIA, for the sole purpose of the proper execution of the Services, within the limits of the contractual conditions signed between CYRIA and the subcontractor, and which may not derogate from the conditions of the present Privacy Policy: host, technical service providers, commercial partners.

CYRIA declares:

Have given written instructions concerning the processing of Personal Data by the subcontractor;
To ensure, beforehand and throughout the duration of the processing, that the processor complies with the obligations set out in the European regulation on the protection of Personal Data;
Supervise processing, including audits and inspections of subcontractors.

CYRIA undertakes that the subcontractor :

Processes Personal Data solely for the purpose(s) for which it is subcontracted;
Processes Personal Data in accordance with CYRIA's instructions;
Guarantees the confidentiality of the Personal Data processed;
Has undergone the necessary training in the protection of personal data;
Take into account, with regard to its tools, products, applications or services, the principles of protection of Personal Data by design and protection of Personal Data by default;
Immediately inform CYRIA if it considers that any instruction constitutes a breach of the European Data Protection Regulation or any other provision of Union or Member State law relating to the protection of Personal Data.

Personal Data may also be transmitted to commercial partners who enable CYRIA to properly execute subscriptions, their management, processing and payment under the contractual conditions signed between the partner and CYRIA which cannot derogate from the conditions of the present Privacy Policy.

CYRIA may reuse Personal Data or transmit it to partner companies for the purpose of sending commercial information by e-mail, but only with the express consent of the User.

CYRIA declares that it receives from the subcontractor all documentation necessary to demonstrate compliance with the obligations and to allow audits, including inspections, to be carried out by CYRIA or another auditor appointed by CYRIA, and to contribute to such audits.

CYRIA remains solely responsible to Users for the provision of Services entrusted to a subcontractor.

4.3 CYRIA uses the services of Titan Datacenters France SAS located at 45 Allée des Ormes E. Space Park Bâtiment D, 06250 Mougins.

Pursuant to Decree no. 2011-219 of February 25, 2011 on the retention and communication of data identifying any person who has contributed to the creation of content posted online, the User is hereby informed that the Platform host is obliged to retain for a period of one year from the date of content creation, for each operation contributing to the creation of content:

The identifier of the connection at the origin of the communication ;
The identifier assigned by the information system to the content, the object of the operation;
The types of protocols used to connect to the service and transfer content;
The nature of the operation ;
Date and time of operation ;
The identifier used by the originator of the transaction, if provided.

In the event of termination of the contract, the host must also retain for a period of one year from the date of termination of the contract the information provided at the time of subscription to a contract (order) by the User or at the time of creation of a customer space, namely :

When creating the customer area: the login for this connection;
Full name or company name ;
Associated postal addresses;
The pseudonyms used ;
Associated e-mail or account addresses ;
Telephone numbers ;
The password and the information needed to verify or change it, in their last updated version.

Lastly, when the contract (order) is subject to a fee, the Platform host must keep the following information relating to the payment, for each invoice or payment transaction, for a period of one year from the date of issue of the invoice or payment transaction:

The type of payment used;
Payment reference ;
The amount ;
Transaction date and time.

ARTICLE 5: PROTECTION OF PERSONAL DATA - USERS' RIGHTS

5.1 CYRIA ensures that the Personal Data is adequately and appropriately secured and has taken the necessary precautions to preserve the security and confidentiality of the data and in particular to prevent it from being distorted, damaged or communicated to unauthorized persons.

CYRIA will implement all the technical and organizational measures necessary to respect the protection of personal data, to fight against unauthorized processing.

When CYRIA becomes aware of a violation of rights in connection with the processing of Personal Data, this violation will be notified to the CNIL within a period not exceeding seventy-two (72) hours of becoming aware of it.

CYRIA will notify the User by e-mail within one (1) month of any breach in the processing of Personal Data.

5.2 In all cases, Users have the right to access, rectify, modify, oppose, port and delete Personal Data. These rights may be exercised by contacting CYRIA at the following address: [email protected] indicating the surname, first name, home address, e-mail address and telephone number of the User, as well as the subject of the request.

In accordance with current regulations, all requests must be signed and accompanied by a photocopy of an identity document bearing the User's signature, if requested by CYRIA.

The right to portability is limited to the data provided by the User concerned and applies on the basis of the User's prior consent. Upon request, CYRIA undertakes to transmit within 30 days, and in an open and readable format, any document collecting Personal Data to the User in order to be able to implement the right to portability. The cost of recovering the data shall be borne by the User making the request.

ARTICLE 6: COOKIES

6.1 CYRIA may use cookies when Users use the Services on the Platform.

6.2 Some cookies are essential for the User to be able to take advantage of all the features of the Platform and do not collect confidential information about Users.

In accordance with CNIL deliberation no. 2013-378 of December 5, 2013, CYRIA informs Users that cookies record certain information that is stored in the memory of their computer hardware/equipment. This information is used to improve the use and operation of the Platform, but also to understand how the Platform is used by Users, as well as the tools and services CYRIA makes available to them. An alert message informs each person visiting the Platform of the presence of these essential cookies.

6.3 The Platform also uses third-party cookies for non-essential purposes to understand how the Platform works and how the User interacts with the Platform, to provide advertising that is relevant to the User and overall to provide a better and improved User experience and to speed up Users' future interactions with the Platform.

The third-party cookies present on the Platform are the following:

Statistical cookies: These cookies store information such as the number of visitors to the Platform, the number of unique visitors, which pages of the Platform have been visited, the source of the visit, and so on. This data helps CYRIA to understand and analyze the performance of the Platform and how it can be improved.
Marketing cookies: These cookies are used to personalize the advertisements displayed on the Platform so that they are meaningful to the User, and help the Platform track the effectiveness of these advertising campaigns. The information stored in these cookies may also be used by third-party advertising providers to display ads on other websites on the browser.
Functional cookies: These are cookies that help certain non-essential functions of the Platform, including the integration of content such as videos or the sharing of content on the Platform.
Preferences cookies: These cookies help CYRIA to store Users' browsing settings and preferences so that they have a better experience when they visit the Platform in the future.

6.4 To guarantee the User's free, informed and unequivocal consent, the User visiting the home page or another page of the Platform directly from a search engine will be informed:

Specific purposes of the cookies used ;
The possibility of objecting to these cookies and changing the settings by clicking on a link in the banner;
And of the fact that the continuation of its navigation does not mean agreement to the deposit of cookies on its terminal. The banner will not disappear until the user accepts or refuses to accept and read cookies.

6.5 Unless the User has given his/her prior consent, cookies will not be deposited or read:

If he/she goes to the Platform (home page or directly to another page of the Platform) and continues browsing: a simple absence of action cannot be assimilated to a manifestation of will;
Or if they click on the link in the banner allowing them to configure their cookies and, if necessary, refuse the deposit of cookies.

6.7 The User may at any time choose to deactivate cookies and other tracking devices. The User's browser can be configured to notify him/her of cookies placed on his/her terminal, and to ask him/her whether or not to accept them.

The configuration of each browser is different. It is described in the browser's help menu, which will tell the User how to modify his or her cookie preferences.

"Firefox: https://support.mozilla.org/fr/kb/cookies-informations-sites-enregistrent

Click on the menu button and select "Options".
Select the "Privacy" panel.
Set the "Retention rules" menu to "Use custom settings for history".
Uncheck the "Accept cookies" box.
Any changes you have made will be automatically saved..
"Internet Explorer : https://support.microsoft.com/en-us/products/windows?os=windows-7
Click on the Tools button, then on "Internet Options".
Click on the "Privacy" tab, then under "Settings", move the slider up to block all cookies or down to allow all cookies, then click OK.
"Google Chrome: https://support.google.com/chrome/answer/95647?hl=fr
Select the Chrome menu icon.
Select "Settings".
At the bottom of the page, select "Show advanced settings".
In the "Privacy" section, select "Content settings".
Select "Prohibit all sites from storing data".
Select OK.

"Safari: https://www.apple.com/legal/privacy/fr-ww/cookies/

Click on "Settings" > "Safari" > "Privacy" > "Cookies and website data".