Updated on 24/07/2024
Within the scope of its activity, PAATCH, a simplified joint stock company with capital of 1,000 euros, having its registered office at 24 rue de Clichy - 75009 Paris, registered under the unique identification number 911 060 176 R.C.S.Paris, represented by its Chairman, Mr Niels Rolland, duly authorized for the purposes hereof (hereinafter the "Company") collects and processes personal data for the purpose of providing information and services to its contributors and partners. This privacy policy is intended to govern the processing of personal data by the Company.
I-Imprint
https://www.paat.ch is a publication of : PAATCH
Simplified joint stock company with a capital of 1,000 euros
Head office: 24 rue de Clichy - 75009 Paris
Registered under number 911 060 176 R.C.S. Paris
VAT :FR94911060176
Contact: rgpd@paat.ch
Data Protection Officer: Mr Niels Rolland
Website host: OVH
II-Personal dataprotectionPreamble
TheCompany, the recipient of the data collected, undertakes to respect and protect your privacy in the context of your use of its website https://www.paat.ch (hereinafter the "Website") and its products and services (as defined in the General Terms and Conditions and hereinafter collectively referred to as the " Services").
Operating in France, the Company is committed to complying with current legislation and regulations on the protection of personal data, and in particular :
● Regulation EU 2016/679 of the European Parliament and of the Council of April 27, 2016on the protection of individuals with regard to the processing of personal data (RGPD);
● the French Data Protection Act (Loi Informatique et Libertés) and Decree no. 2005-1309 of October 20, 2005 on the protection of personal data, amending Act no. 78-17 of January 6, 1978 on data processing, data files and individual liberties, and various provisions concerning the protection of personal data;In accordance with the regulations in force, the data controller undertakes to process the personal data of its users fairly, lawfully and transparently, for specific, explicit and legitimate purposes.
1- Definitions
Personal data(hereinafter " Personal Data "),are defined according to Article 4 §1 of the RGPD as any information will be related to an identified or identifiable natural person. The processing of personal data (hereinafter " Processing ") is defined according to Article 4 §2 of the RGPD, as any operation or set of operations carried out using automated processes and applied to data or sets of data such as, in particular, collection, recording, storage, consultation, use. The user (hereinafter "User") is designated, within the meaning of Article 4 1) of the RGPD, as a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, an online identifier.
2-Person responsible for processing the Personal Data collected
Mr. Niels Rolland acts as data controller in the collection and processing of Personal Data. In its capacity as data controller, Mr Niels Rolland ensures a high level of protection for the Personal Data of the Service Users concerned at all stages of processing, including but not limited to collection, storage and destruction.
3-Personal data processed
3.1 Personal Data provided by the User
Whenregistering, the User must create a customer account (as defined in the General Terms and Conditions) enabling him/her to connect to it in order to access the content of the Services. The User is required to enter and provide certain information which is considered to be Personal Data. In accordance with the principle of deminimization and protection of privacy by default, only Data necessary for the fulfillment of the following purposes are collected: Data transmitted directly by the User, including but not limited to:
● Data required to register for the Services, i.e. surname(s), first name(s), e-mail address, telephone number and password, billing address;
● Additional Data relating to marital status and the name of the company in whose name the Customer Account is created. This Data is used to personalize the User's account and its relationship with the Services;
● Subscription to the newsletter using the User's surname, first name and e-mail address;
● The IP address, device model, browser and language of the device with which the User connects to the Services;
● Photograph, curriculum vitae and letter of motivation in response to job offers from the Company;
● Responses to surveys in which the User may be invited to participate, and the content of his/her publications and opinions. This information may be used for research and analysis of the User's behavior, in order to improve the Services;
● Details of transactions and orders made by the User through the Services;
● Details of visits related to the use of the Services on the various platforms, including but not limited to traffic data, location data, resources consulted and other communication data, if required for billing purposes;
● The history of User communications on the tools made available to them, between themselves and with the Company;
● Information from the User's social network profile if the User chooses to connect to the Services via these channels;
● Any other information that the User wishes to bring to the attention of the Company.
3.2 Personal Data collected automatically
Cookies Cookies are collected automatically, whether technical cookies necessary for navigation, strategic cookies, and on the basis of consent advertising cookies or those necessary for redirection to social networks. The deposit of cookies that are not essential to the operation of the Website requires your consent, as does the processing of Personal Data deduced from these cookies. You will be asked for your consent when you first visit a page on the Website. You can modify your preferences at any time, and in particular withdraw your consent, by clicking on the "cookie settings" icon on the home page of the Website. For further information, please refer to paragraph III "Cookie Usage Policy". Personal Data linked to social networks When the User accesses the Company's social networks by clicking on the redirection icons on the Website, and if the User is already connected to one of these social networks, the User's e-mail address, surname, first name, username as entered when creating the account in question, as well as the account data used in accordance with the general terms of use of the social network in question, are collected. Use of the Services Log files enable us to record the User's use of the Services. This allows us to analyze the User's needs and improve the Services accordingly.
4-The purpose of processing Personal Data
Underthe principle of Data minimization provided for in Article 5 c) of the RGPD, only the datanecessary to accomplish previously established purposes, the performance of the Company's contractual obligations and the satisfaction of the User's requests are collected. Thus, the processing of PersonalData is established for the following purposes:
● access to and provision of Services;
● the execution of online payment agreements in order to enable the performance of contractual obligations under Article 6 §1 c) of the RGPD ;
● inform the User of the interactive features of the Services if requested by the User;
● provide a history of the content consulted by the User;
● analyze messages - publications and notices left by Users in order to ensure that the General Terms and Conditions of Use and the General Terms and Conditions of Sale are complied with;
● the possibility of subscribing to a newsletter and occasional special offers subject to the User's consent;
● the collection of cookies on the basis of consent, with the exception of technical cookies strictly necessary for the operation of the Services;
● the provision of statistical data for the purpose of improving the Services and the Website.
The User may withdraw his consent at any time via his personal space, by sending his request by e-mail to the following contact address: rgpd@paat.ch The collection and processing of Personal Data also enables us to respond to requests for access, rectification, opposition or other rights in respect of the User's Personal Data. This processing is then based on compliance with legal obligations. Finally, certain other cases are justified by the Company's legitimate interests:
● improve and optimize the Services, in particular to ensure that the display of content is compatible with the devices used by Users;
● management of internal technical operations as part of problem solving, data analysis, testing, research, studies and surveys to ensure the safety of the Services;
● manage notices, incidents, claims and disputes and, consequently, exercise and defend the Company's rights before the courts;
● measure the performance of marketing efforts to develop and sustain Services.
5-Retention period of Personal Data
UnderArticle 5 d) of the RGPD, Personal Data collected and processed for the aforementioned purposes areconserved for a limited period of time and strictly necessary to achieve the intended purposes.
Dataconcerned: Identification data,
Purposes: Operation and access to the Customer Account on
Legal basisfor processing: User consent through acceptance of the Privacy Policy and the Company's legitimate interest in providing access to the Website and Services
Retention period: 3 years from the last contact with the UserNewsletter dataInformation on the latest news
Data concerned:Identification data Information and commercial prospecting
Purposes: Prospecting
Legal basisfor processing: User consent
Retention period: Retention until unsubscriptionDataconcerned : Data relating to financial transactions and contact details
Purposes : Fulfilment of contractual obligations and connection to Customer Account
Legal basisfor processing: Consent of the User through acceptance of the Privacy Policy and the Company's legitimate interest in providing access to the Website and Services
Retention period: Life of the contract plus the applicable statute of limitations
Data concerned: Browsing data
Purposes: Collection of cookies when browsing the Website
Legal basisfor processing: User consent
Retention period: 13 months from collection
Data concerned: Professional data
Purpose: to apply for a job
Legal basisfor processing: User consent
Retention period: 2 years from last contact with candidate
Data concerned: History of exchanges
Purposes: Website management
Legal basisfor processing: User consent through acceptance of the Privacy Policy and the Company's legitimate interest in providing access to the Website and Services
Ret ention period: 3 years from the last contact with the User
6 - Personal Data protection measures
TheCompany undertakes to take all technical and organizational measures to ensure the protection and security, integrity and confidentiality ofPersonal Data, and in particular against any loss, alteration, dissemination or unlawful use. The Company ensures that such measures are in place for all operations carried out as part of its processing operations, and in particular for the collection, storage and hosting of Personal Data. In this respect, the Company also ensures that any third parties it may call upon (payment service providers, technical service providers, suppliers, hosts)comply with this requirement to protect the User's Personal Data by implementing appropriate measures, in accordance with theRGPD. The technical and organizational measures implemented mayinclude the use of secure registration forms, encryption and/or restricted access to Personal Data. The Company urges the User to exercise the utmost caution when communicating Personal Data, as well as personal identifiers and passwords enabling access to the Services, to third parties. Certain messages or solicitations received may come from malicious persons seeking to obtain personal information concerning the User with a view to fraudulent use. If the User receives a message that appears to be an attempt at fraud, he/she is invited not to reply and not to open any attachments, images or links contained in the message.
7- Transfer of Personal Data
7.1 General information
In the course of its business activities, the Company may call on the services of subcontractors, for whom it undertakes to maintain an adequate level of protection. Personal Data is processed internally, but may also be communicated to the following external recipients:
● financial institutions holding allocated accounts ;
● competent administrative and judicial authorities ;
● judicial and/or ministerial officers as part of their debt collection mission;
● subcontractors (in particular IT and payment service providers) and external service providers (such as auditors, legal advisors, trustees, providers of analytical solutions or payment services, companies and organizations specializing in fraud protection and reducing the risk of non-payment, etc.), to the extent strictly necessary and subject to the existence of contractual guarantees suitable for ensuring the security and confidentiality of data in accordance with the RGPD ;
● at the User's express request ;
● in the event that the Company is acquired by a third party, the Personal Data will be transmitted to the purchaser;
● in all cases where the User chooses to make the Personal Data public. Furthermore, all transfers of Personal Data to subcontractors located outside the European Union are supervised and present all appropriate guarantees, in particular through the European Commission's contractual clauses, which ensure an adequate level of protection and the protection of the User's fundamental rights. The Company's subcontractors (partners and third-party technical service providers), who have their own confidentiality policies to which the User is invited to refer. In any event, these partners are authorized to use Personal Data only in the context of the services they perform on behalf of the Company and solely for the purposes set out herein.Subcontractor : StripeActivity: Payment service providerPrivacy policy: https: //support.stripe.com/questions/privacy-and-security-of-personal-information-submitted-to-stripe?locale=fr-FR
Subcontractor: OVH / AWSActivity: Platform hosting https://www.paat.ch
7.2 Payment service provider
Inorder to be able to book and benefit from Services on the Website, eachUser must create a password-protected Customer Account. This contains an overview of reserved Services and active transactions. The password and all identifiers are confidential data and are under the User's protection. In addition, it is necessary for the subscription(s), that the User will have to communicate other Data, used for the processing of the order. These details are marked separately. For payment processing, the Company uses the following payment service provider: Stripe Payments Europe Limited, a limited liability company incorporated in Ireland, having its registered office at Block 4, Regus Harcourt Centre, Harcourt Road, Dublin 2 - Ireland, registered with the Registrar of Companies of Ireland under number 513174, represented by Mr Jon Zieger. The Company does not collect any payment data from its Users through the use of the STRIPE platform. For more details on the provisions applicable to the processing of your personal payment data, the User is invited to consult STRIPE's privacy policy under this link: https://support.stripe.com/questions/privacy-and-security-of-personal-information-submitted-to-stripe?locale=fr-FR The processing of the data entered is carried out for the execution of the payment (art. 6 paragraph 1lit. b RGPD). The data will be processed in this context for as long as is necessary to achieve the objectives pursued. Thereafter, they will be deleted, provided there is no legal obligation to retain them. Processing does not take place outside the European Union (EU) or the European Economic Area (EEA). For all intents and purposes, the Company does not use automated decision-making or profiling for this data processing.
7.3 External links
Variousexternal links to other websites are present on the SiteInternet. In the event that the User clicks on one of these links and is referred to the external sites, the Company shall not be held liable for any prejudice whatsoever and for the processing of the User's Personal Data by these third parties.
7.3.1 Social networks
The Company is present on social networks in order to inform Users of itsServices and to communicate directly via these platforms. The Company is currently represented on the following networks: Facebook: https://www.facebook.com/paatchlife/Instagram : https://www.instagram.com/paatchlife/?hl=frLinkedIn :https://www.linkedin.com/company/paatch/TikTok : https://www.tiktok.com/@paatchlife All these social networking channels are accessible to Users of the Website via an external link. The Company has no influence over the collection and use of Personal Data by these social networks. Consequently, the Company has no control over the management, processing and collection of Personal Data and cannot be held responsible for the extent, location or duration of retention of Personal Data by these social networks. The Company therefore expressly draws the User's attention to the fact that his or her Personal Data (such as personal information and IP address) is stored by network operators in accordance with their own data usage guidelines and used for commercial purposes. The legal basis for the processing of user data is Article 6 paragraph.1(b) and (f) of the GDPR. Information specific to Facebook/Instagram The User can access the Facebook/Instagram social media network via external links on the Website. All functions of the social media network are provided by Meta Platforms Inc, 1601 South California Avenue, Palo Alto, CA 94304, USA. Meta channels can only be accessed via an external link. If the User is logged in to Facebook/Instagram with his/her personal profile and wishes to access the Company's social media channel, Facebook/Instagram may assign his/her site to his/her login profile. If the User does not wish his/her account to be associated with his/her IP address, he/she is reminded that he/she can disconnect from his/her Facebook/Instagram account before using the Website. For further information on the processing of your data, please consult Meta's privacy policy: https://fr-fr.facebook.com/help/instagram/155833707900388 Information specific to LinkedIn LinkedIn channels can only be accessed via an external link. If Users of the Website are members of the LinkedIn platform, LinkedIn may attribute the visit to the social media channel to the User's profile if the User visits our LinkedIn profile while logged in to his/her personal account. LinkedIn is certified under the Privacy Shield agreement and thus offers a guarantee of compliance with European data protection legislation. Please note that the Company has no influence over the content, scope of use or data collected by LinkedIn Ireland UnlimitedCompany. For further information, please visit the LinkedIn Ireland Unlimited Company website at https://fr.linkedin.com/legal/privacy-policy?trk=hb_ft_priv. Please note that the User is free to make any changes he/she wishes to his/her LinkedIn account in order to protect his/her privacy. Information specific to TikTok The User may access the TikTok social media network via an external link on the Website. All functions of the social media network are provided byByteDance, headquartered in Beijing, China, with a branch at 19 rue Poissonnière - 75002 Paris. TheTikTok channels are only accessible via an external link. If the User is connected to TikTok with his/her personal profile and wishes to access the Company's social media channels, TikTok may attribute his/her visit to his/her connection profile. If the User does not wish his account to be associated with his IP address, he is reminded that he can log out of his TikTok account before using the Website. For further information on the processing of your personal data, please consult TikTok's privacy policy: https://www.tiktok.com/legal/page/eea/new-privacy-policy/fr
7.3.2 Partner sites
The User may also consult the websites of the Company's partners by clicking on the external links redirecting to said websites. There is no relationship of subordination, de facto partnership or group of interest between the Company and its partners. The latter are solely responsible for the collection and processing of Personal Data on their platform(s), and the Company shall not be held liable for any damage caused to the User as a result of visiting these partner websites.
7.2.3 User websites
Within the framework of the execution of the Services, and in particular the promotion of its contents, and/or on the occasion of discussions between and with Users and/or the execution of the Services (as these terms are defined in the General Terms and Conditions of Sale) by indicating external redirection links to the website(s) of said Users. There is no relationship of subordination, de facto partnership or group of interest between the Company and its Users. The latter are solely responsible for the collection and processing of Personal Data on their platform(s), and the Company shall not be held liable for any damage caused to the User as a result of visiting these websites.
8- User rights
The User may modify his Personal Data at any time via his Customer Account. He may also ask the Company not to use his Personal Data for marketing purposes. The User has a right of access, information, rectification and opposition, as well as deletion and portability when his Data has been collected on the basis of his consent and/or in the performance of a contractual obligation. The User also has the right to limit processing in certain cases, as well as the right to file directives concerning the fate of his or her Data after his or her death. To do so, the User must send a request, with proof of identity (surname - first name or name of the company he/she represents), to the following e-mail address: rgpd@paat.ch. In the event of dispute, the User concerned has the right to make a request directly to the competent supervisory authority, the CNIL.
9- Minors' privacy
TheServices are designed for Users aged 18 and over. Non-emancipated minors may use the Services but their use must be carried out only under the supervision, control and with the consent of their legal representatives.
10 -Modification of the Privacy Policy
The Company reserves the right to modify or update this Privacy Policy, or any other of its policies or practices, at any time, and to inform Users of the Services by posting the updated Privacy Policy on its home page along with the date of the update. Any modification will be effective immediately upon such posting. Use of the Services constitutes the User's agreement to abide by the Privacy Policy in question as modified. In certain circumstances, if Personal Data is to be used for purposes other than those indicated herein, and where necessary, the Company will seek the User's consent (or renewal thereof).
III- Cookie use policy
Acookie is a small file deposited and read when a website or mobile application is consulted, regardless of the type of terminal used (telephone, computer, tablet, etc.). Its purpose is to collect information relating to the User's browsing and to send him or her tailored content. Only the sender of a cookie is able to read the information contained in it, for the duration of its validity. The deposit of non-purely technical cookies is subject to the User's consent. In order to manage cookies as closely as possible to the User's wishes, the User is invited to take into account the purposes of cookies, specified below, when setting parameters. The Services use cookies for the following purposes:
● Purely technical and necessary for the operation of the Services: these cookies enable the Services to function optimally and securely. They also make it possible to memorize some of the User's choices;
● Security cookies;
● With the User's consent, authentication cookies, which exempt the User from having to provide his/her login and password each time he/she connects to the Services;
● Social networks: to check whether the User is connected to third-party social networks;
● Website improvement;
● Audience measurement: to pursue statistical data on the frequentation of the Services and to enable the study of the effectiveness of interactive online content, its features, advertising and other communications. Through these cookies, third parties may collect and use the User's browsing data for their own purposes, in accordance with their own privacy policies. The Company shall not be held liable for any use of personal data collected by a third party that is contrary to legal and regulatory provisions. The User may withdraw his/her consent, at any time, to the deposit of cookies during his/her browsing on the Company's platforms.