Privacy Policy

Preamble

The Communauté du Pays Voironnais processes personal data (hereinafter the "Personal Data)" concerning you in the context of the use of this website (hereinafter the "Site").
As data controller, we respect privacy and protect the personal data of users of our Site.
This policy aims to inform you of the methods of collection, processing and use of Personal Data and of your rights in terms of protection of personal data with regard to the applicable provisions in this matter, in particular Law 78-17. of January 6, 1978 relating to data processing, files and freedoms known as "Data processing and freedoms" in its latest version and with France's General Data Protection Regulations, in force since May 25, 2018.

Article 1 - Scope of this personal data protection policy

This Policy sets out the principles and guidelines for the protection of Your Personal Data, which includes Personal Data collected on - or through - the Site.

The Community of Pays Voironnais collects Personal Data (online, including by e-mail, or offline); this policy applies regardless of the method of collection or processing.

The notion of Personal Data refers to any information relating to an identified or identifiable natural person. A person is “identifiable” when they can be identified, directly or indirectly, in particular by reference to an identification number, or to one or more elements which are specific to them.

“Non-Personal Data” corresponds to information that does not allow a person to be identified.

Article 2 - Places of storage of Personal Data

All Personal Data is stored exclusively in France, by our web hosting provider:

OVH
2 Roubaix
59100 Roubaix - France
www.ovh.com

Article 3 - Data controller

The person responsible for processing Your Personal Data is: Pays Voironnais Urban Community – CS 80363 – 40 rue Mainssieux – 38516 Voiron cedex; certain technical services (Hosting) are entrusted to our technical service providers (IRIS Interactive). In accordance with Article 28 of the GDPR, this service provider is bound by a strict confidentiality clause which prohibits any use of the data entrusted to it not provided for in the service contract and which requires it to implement technical and organizational arrangements that meet security and personal data protection requirements.

Article 4 - Data collected

Personal data

Personal Data may include the following:

• Last name,
• first name,
• email address,
• address,
• phone number,
• number of people in the household,
• IP adress,
• order history

And any other Personal Data that may be relevant for the purposes set out below.

Note to the attention of visitors and users of the Site: certain functionalities and characteristics of the Site can only be used if You communicate to La Communauté du Pays Voironnais certain Personal Data when You visit or use the Site. You are free to provide or not, all or part of Your Personal Data.

However, if You choose not to provide them, such a decision could prevent the satisfactory achievement of the objectives described below, certain services and certain functionalities of the Site could not function correctly and/or You will be denied access to certain pages of the Site.

Cookies and other trackers

The Site may use cookies or other technologies likely to collect or store Personal Data. Cookies are text files stored and used to record Personal and Non-Personal Data concerning browsing on the Site.

Cookies can be permanent (and remain after the user has disconnected from the Site, in order to be used during subsequent visits to the Site) or temporary (and disappear as soon as the user disconnects from the Site).

The Communauté du Pays Voironnais uses cookies to improve your user experience, in particular by:

• allowing a service to recognise an individual user's equipment, so that person will not have to provide the same information several times in order to perform the same task;

The Communauté du Pays Voironnais uses cookies to analyze traffic and data on the Sites in order to:

• measure the number of users of the services, thus making them easier to use and ensuring their ability to respond quickly to requests;
• help the Pays Voironnais Community understand the way in which users interact with the services in order to improve them.

The Communauté du Pays Voironnais may also use the services of third-party service providers for the purpose of performing the services on its behalf and in particular for:

• analyse individual browsing habits and measure the audience of the Sites and Applications;
• analyze Your areas of interest;
• allow an individual to share the content of the Applications' Sites with other people on social networks or to let these other people know what a user is watching or what they think (eg the "Like" button on Facebook)

In this case, pixel tags and cookies provided by these third-party providers may be used and stored. When transmitting the information generated by these cookies, the cookie settings ensure that the IP address is anonymized before geolocation and before storage. Our service providers will use this information to evaluate Your use of the Site, to write reports on the activity of the Site for the Community of the Pays Voironnais. They will not associate your IP address with any other of their data.

When you browse the Site, cookies are enabled by default and data can be read or stored locally on your hardware. You will be notified the first time You receive a cookie and You can decide whether to accept or reject it.

Any individual can also configure their browser to systematically refuse cookies (including cookies used for audience measurement purposes). However, if this were the case, certain functionalities and features of the Site may not function properly and that individual may not be able to access certain parts or services of the Site.

The cookies placed on the site are as follows:

Technical cookies necessary for the operation of the site:

Cookies necessary for audience measurement:

If any individual wishes to modify or delete information, please refer to Article 8: Your rights.

It's possible to access the cookie management panel to configure the storage and reading of cookies.

Data retention

By type of data:

• Civil status data (surname, first name, postal address, etc.): 3 years;
• Connection data: 3 years;
• Location data = 48h;

We only keep Personal Data for a period of time necessary and proportionate to the purpose for which it was collected, namely for a maximum period of 3 years from the last exchange you had with us and carried out at your initiative.
Beyond the aforementioned periods, your data will be purely deleted or anonymised.

Article 5 - Purposes of the collection of personal data

As indicated above, You provide Your Personal Data on a voluntary basis.
Personal Data is generally collected for the needs of the activity of La Communauté du Pays Voironnais such as improving the site of the Pays Voironnais, better adapting the products and services of La Communauté du Pays Voironnais to the needs of users or respecting statutory reporting requirements, and other similar activities.
The Communauté du Pays Voironnais collects and uses Personal Data concerning You for the purposes of its activity and in particular for the following purposes:

We process a user's data in whole or in part for the purposes of:

• management of the relationship with the visitor in the event of a request for information and purchase;
• newsletter dispatch management;
• statistical operations, analysis, in order to improve knowledge of visitors;
• measurement of site traffic;

Article 6 - Conditions for processing and storing personal data

The "processing" of Personal Data includes in particular the use, conservation, recording, transfer, adaptation, analysis, modification, declaration, sharing and destruction of Personal Data depending on what is necessary in view of the circumstances or legal requirements.

All Personal Data collected is kept for a limited period depending on the purpose of the processing and only for the period provided for by the applicable legislation.

All Personal Data collected is stored in Europe.

Article 7 – Links to websites not controlled by the Community of the Pays Voironnais

The Site may provide links to third party websites that may be of interest to its users.

The Communauté du Pays Voironnais has no control over the content of third-party sites or the practices of these third parties with regard to the protection of Personal Data that they may collect. Consequently, La Communauté du Pays Voironnais declines all responsibility concerning the processing by these third parties of Your Personal Data. It is your responsibility to find out about the personal data protection policies of these third parties.

Article 8 - Transfer of personal data

In the event of access to the Site from a country which is not a member of the European Union whose legislation relating to the collection, use and transfer of data differs from those of the European Union, we draw the individual's attention to the fact that by continuing to use the Site, which is governed by French law, the corresponding Terms of Use and this Policy, Personal Data is transferred to the European Union and the user consents to this transfer.

Your Personal Data may be disclosed within La Communauté du Pays Voironnais for the purposes set out in Article 3 of this Policy.

If La Communauté du Pays Voironnais learns that a third party to whom La Communauté du Pays Voironnais has communicated Personal Data for the purposes set out in Article 3 above, is using or disclosing Personal Data without respecting this Policy or in violation of the applicable law, La Communauté du Pays Voironnais would take all reasonable measures to prevent or put an end to such use or disclosure.

You also have the right to authorize or refuse La Communauté du Pays Voironnais to use Your Personal Data for a purpose other than that for which this Personal Data was initially collected. You can object to this use by referring to Article 8 below.

The Communauté du Pays Voironnais may communicate Your Personal Data if the law requires it or if the Community of the Pays Voironnais considers in good faith that such disclosure is reasonably necessary to comply with a legal procedure (for example, a mandate , a subpoena or any other court decision) or to protect the rights, property or personal safety of La Communauté du Pays Voironnais of our customers or the public.

Article 9 - Your rights

Your right to access and rectify your data

You have the right to access and have your personal data corrected.

You can ask us that your personal data be, depending on the case, rectified, completed if they are inaccurate, incomplete, equivocal or out of date.

Your right to have your data deleted

You can ask us to erase your personal data when one of the following reasons applies:

• the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
• you withdraw the consent previously given;
• you object to the processing of your personal data for legitimate reasons;
• the processing of personal data does not comply with the provisions of applicable law and regulations.

Nevertheless, the exercise of this right will not be possible when the conservation of your personal data is necessary with regard to the legislation or the regulations and in particular for example for the establishment, the exercise or the defence of rights in court.

Your right to limit data processing

You can request the limitation of the processing of your personal data in the cases provided for by law and regulation.

Your right to object to data processing

You have the right to object to the processing of personal data concerning you when the processing is based on the legitimate interest of the controller.

Your right to the portability of your data

Since May 25, 2018, you have the right to the portability of your personal data.

The data on which this right can be exercised are:

• only your personal data, which excludes anonymised personal data or data that does not concern you;
• declarative personal data as well as the personal operating data mentioned above;
• personal data which does not infringe the rights and freedoms of third parties, such as those protected by business secrecy.

This right is limited to processing based on consent or on a contract as well as personal data that you have personally generated.

This right does not include derived data or inferred data, which are personal data created by the Communauté du Pays Voironnais.

Your right to withdraw your consent

When the data processing that we carry out is based on your consent, you can withdraw it at any time. We then stop processing your personal data without the previous operations for which you had consented being called into question.

Your right to lodge an appeal

You have the right to lodge a complaint with the CNIL on French territory, without prejudice to any other administrative or judicial appeal.

Your right to set post-mortem guidelines

You have the possibility to define guidelines relating to the conservation, erasure and communication of your personal data after your death and this with a trusted third party, certified and responsible for ensuring that the will of the deceased is respected in accordance with the requirements of the applicable legal framework.

How to exercise your rights

All the rights listed above can be exercised:

• by post to the following address: Communauté du Pays Voironnais – At the attention of the DPO – BP 80363 – 40 rue Mainssieux – 38516 Voiron cedex, enclosing a copy of your identity card and proof of address;
• via our email address dpo@paysvoironnais.com A procedure will then be sent to you in order to validate your identity.

Note: the supporting documents sent as part of this procedure will be purely destroyed after verification. Your rights exercise letter will be kept for 6 years from your request.

Also note that any requests that do not meet these guidelines will be ignored.

We undertake to respond to these requests within 1 month of receipt of the request. This period may be extended by 2 months depending on the complexity and the number of requests received, i.e. 3 months in total.

However, with regard to the exercise of the right to information, we may not have the obligation to act on it if:

• you already have this information;
• the recording or communication of your personal data is expressly provided for by law;
• communication of information proves impossible;
• providing information would require disproportionate effort.

Article 10 - Data security and recipients

The Communauté du Pays Voironnais takes care to protect and secure the Personal Data that You have chosen to communicate to it, in order to ensure their confidentiality and prevent them from being distorted, damaged, destroyed or disclosed to unauthorized third parties.

The Pays Voironnais Community has taken physical, electronic and organizational protection measures to prevent any loss, misuse, unauthorized access or dissemination, alteration or possible destruction of this Personal Data. Among these protection measures, La Communauté du Pays Voironnais incorporates technologies specially designed to protect Personal Data during their transfer. However, despite the efforts of La Communauté du Pays Voironnais to protect Your Personal Data, La Communauté du Pays Voironnais cannot guarantee the infallibility of this protection due to inevitable risks that may arise during the transmission of Personal Data.

As all Personal Data is confidential, access to it is limited to employees and service providers of La Communauté du Pays Voironnais who need it in the performance of their mission. All persons having access to Your Personal Data are bound by an obligation of confidentiality and expose themselves to disciplinary measures and/or other sanctions if they do not respect these obligations.

However, it is important that You exercise caution to prevent unauthorized access to Your Personal Data. Consequently, You must ensure that You close Your session in the event of shared use of the same computer or the same terminal.

Article 11 - Conflict resolution

Although La Communauté du Pays Voironnais has taken reasonable measures to protect Personal Data, no transmission or storage technology is completely infallible.

However, the Community of the Pays Voironnais is concerned to guarantee the protection of Personal Data. If You have reason to believe that the security of Your Personal Data has been compromised or that it has been misused, You are invited to contact La Communauté du Pays Voironnais at the following address: dpo@ paysvoironnais.com

The Pays Voironnais Community will investigate complaints concerning the use and disclosure of Personal Data and will attempt to resolve them in accordance with the principles set out in this Policy.

Unauthorised access to Personal Data or its misuse may constitute an offence under local law.

Article 12 - Contact

For any question concerning this Policy, to no longer receive information from La Communauté du Pays Voironnais or for any request for rectification, addition, update or deletion of Your Personal Data, You can send an e-mail to the following email address: dpo@paysvoironnais.com

Article 13 - Date of entry into force and revisions of the personal data protection policy

This Policy may be updated according to the needs of La Communauté du Pays Voironnais and circumstances or if required by law. We therefore invite you to regularly check for updates.

Last modified: 16/11/2021