Sleede protects the privacy of all users of its Website in its capacity as a data controller within the meaning of French Act No. 78-17 of 6 January 1978 as amended (hereinafter the “French Data Protection Act”).
The main aim of this Confidentiality Policy is to inform You about the following aspects of any Personal Data processing carried out by Sleede as the data controller in connection with the Website www.homiestrip.com:
– the procedures used to collect and process Your Personal Data;
– the manner in which Sleede uses Your Personal Data;
– the steps it takes to protect Your Personal Data collected when You use the Website; and
The terms defined below will have the following meaning, in both the singular and the plural:
– “Personal Data” means, under Article 2 of the French Data Protection Act: “any information relating to an individual who is or can be identified, directly or indirectly, by reference to an identification number or one or more factors specific to the individual”. In particular, Personal Data includes data that can be used to identify Users. Generally, electronic identification data identifying the Terminal used by You to connect to the Website or the pages You visited on the Website is not sufficient alone to identify You by name.
– “Applicable Regulations” means all regulations and rules, now or hereafter in force, applicable to Users and the Website, mainly the legislation and regulations protecting Personal Data (including the French Data Protection Act).
– “Terminal” means the various devices that may be used to access the Website. In particular, the following are treated as Terminals: smartphones, tablets and individual computers using the Internet (PC or Apple) and any device that is connected or can be connected to another device and the Internet.
– “You”, “Your”, “User(s)” means any person accessing the Website (for example, guests) whose Personal Data may be collected when visiting the Website. Procedures used to collect Personal Data
When You consult the Website, information relating to Your browsing experience may be recorded in cookie files installed on Your Terminal. A cookie is a file installed on Your Terminal, recording information relating to your browsing experience on a website. The data obtained from those cookies is used to enhance Your next visit to the website and also to generate various traffic measurements. Cookies are stored when You browse our Website, either directly by us or by some of our partners (see the section on cookie settings – Section 3.5 Your cookie preferences).
1.2 Cookies installed via the Website
We use the cookies we install on Your Terminal to recognise Your browser when You connect to the Website.
We use them to:
– generate traffic statistics (number of visits, pages consulted and Your route, etc.), in order to help us to continually improve our services;
– store the information entered in various forms.
1.3 Third-party cookies installed via the Website
We sometimes include third-party computer applications on the Website, to allow You to share the content of our Website with other persons, inform them that You have visited content on our Website or share Your opinion with them. For example, we often include “Share” and “Like” buttons for social media such as Facebook, Twitter, LinkedIn and Instagram, etc.
The social media providing the button may identify You using that button, even if You do not click on the button when browsing our Website. Social media can use that type of button to monitor Your activity on our Website if Your account with them was activated on Your Terminal (open session) when You browsed our Website.
We have no control over the processes used by social media to collect information relating to Your activity on our Website, associated with the Personal Data they hold. Please consult the privacy policies of the relevant social media for information on their use (including, for advertising purposes) of the browsing information they may collect through those buttons. In particular, those privacy policies are required to give You an opportunity to choose how they can use Your data, by allowing You to change the settings for Your user accounts with them
We use the following cookies:
o Google Tag Manager (Google Analytics) to manage the statistics of this website. You can check their privacy by clicking the following link: https://policies.google.com/privacy?hl=fr&gl=ZZ
The 3 following cookies are not used by Sleede but can remain in the cache extension of your browser:
o Facebook, You can check their privacy by clicking the following link: https://fr-fr.facebook.com/policies/cookies/
o LinkedIn, You can check their privacy by clicking the following link: https://www.linkedin.com/legal/cookie-policy?_l=fr_FR
o Twitter, You can check their privacy by clicking the following link: https://support.twitter.com/articles/20170518#
1.4 Your cookie preferences
You may decide which cookies You wish to enable and may therefore change the settings of Your browser to disable all cookies or some cookies only (for example, those installed by a certain website). You may also select a prompt option, allowing You to enable or disable specific cookies before they are stored on Your Terminal.
You may select and change Your cookie settings at any time, by following the relevant instructions:
– For Chrome: click on Settings in the menu and then on Advanced. Under Privacy and Security click Content Settings and then select the required option for handling cookies under Cookies.
– For Mozilla Firefox: click on the Tools menu and choose Preferences, select the Privacy & Security panel and go to the History section and then choose Use custom settings for history. Select the required option for handling cookies.
– For Microsoft Internet Explorer 11.0 and later: in the Tools menu select Internet Options and then click on the Privacy tab. Select the required option for handling cookies using the cursor.
– For Opera 6.0 and later: from the main menu, select Settings, click on Privacy & Security in the sidebar and select the required options for handling cookies under Cookies.
– For Safari: in the Safari menu choose Preferences and then click on Security or Privacy and select the required options for handling cookies.
2. Purposes of Personal Data processing
Sleede processes Personal Data via the Website for the following purposes (hereinafter the “Purposes”):
– to answer Your questions or requests for information and process any other requests or applications (for example, recruitment, quotes, student projects and complaints);
– to allow You to monitor the Website and changes to its content (RSS feed).
The information required by Sleede for the above purposes is marked with an asterisk (*) on the relevant pages of the Website. If You fail to complete the required fields marked with an asterisk(*), Your access to all or part of the services and functions of the Website could be blocked and Your requests may not be processed. The other fields are optional and are designed to improve the quality of the service proposed on the Website.
The other information is optional but will allow us to get to know You better and to improve the information and services proposed to You. Sleede collects the following main pieces of information: Your full name, postal address, email address and telephone number.
3. Retention periods for Personal Data
The collected Personal Data is retained for the time required to fulfil the various Purposes described above.
Accordingly, Your Personal Data:
– concerning Your electronic identification is retained for thirty-six (36) months after collection;
– concerning cookies is retained for thirteen (13) months after collection.
The collected Personal Data is erased whenever one of the following events occurs:
– expiry of the retention period;
– exercise of Your right to request the erasure of Your data in accordance with the French Data Protection Act and the procedures set out in the “Access rights to Your Personal Data” section of this Confidentiality Policy;
– discontinuance of the Website by Sleede, for any reason whatsoever.
4. Recipients of Personal Data
For some of the purposes described above, the Personal Data collected by Sleede may be transferred to the following recipients to ensure the operation of the Website and the fulfilment of the Purposes: commercial partners, Sleede's relevant departments and/or services, the departments and/or services of any company belonging to the same group as Sleede, the departments and/or services of any place of business or branch of Sleede or one of the companies belonging to the same group as Sleede.
5. Sharing and disclosure of Personal Data
Sleede is the sole recipient of the collected data. Sleede will only transfer Your Personal Data to a third party in the following cases:
– if You have expressly consented in advance to the sharing of that information (for example, for a special promotional event);
– if Sleede receives an order from a court of law or any other legally competent administrative authority requesting the provision of that information in accordance with the legislation in force.
6. Personal Data spontaneously transferred by Users
You should not transfer any content that has not been requested in a questionnaire or in any other data collection form, such as commercial information, advertisements, Your own personal creations, ideas and concepts etc. Whenever You voluntarily provide Your Personal Data, in particular in the form of multimedia content (photographs and videos, etc.), You agree to provide accurate information that does not harm the interests or infringe the rights of third parties.
7. Security measures
Sleede makes every effort to protect Your Personal Data from any damage, loss, corruption, penetration, disclosure, distortion or destruction. Physical and electronic backup procedures are implemented for the Personal Data collected on the Website, in accordance with the French Personal Data protection legislation in force. Any Sleede employees with access to Your Personal Data for the performance of their duties are bound by absolute confidentiality obligations in this respect. However, Sleede cannot manage all of the inherent risks of the Internet and wishes to draw Your attention to the potential risk of one-off losses of data or breaches of the confidentiality of data transferred online. The information proposed on the Website may be suspended if a force majeure event or any event beyond Sleede’s control occurs or in circumstances that are not attributable to Sleede.
8. Accuracy of Personal Data
You represent that You are fully aware of the importance of providing accurate Personal Data on the Website. Accordingly, You agree not to provide inaccurate Personal Data at any time during the period of Your use of the Website and to immediately update your Personal Data if any changes occur during that period. To that end, You may submit a subject access request or a request for the rectification or erasure of all or part of your Personal Data, as provided for in the “Access rights to Your Personal Data” section of this Confidentiality Policy.
9. Access rights to Your Personal Data
Pursuant to the provisions of Articles 38 to 40 of the French Data Protection Act, You have a general right to access and rectify Your Personal Data processed by Sleede.
You may exercise that right by emailing or posting your request to the address set out below, explaining Your request and enclosing proof of Your identity:
o 25, Rue Gabriel Péri
o 38000 Grenoble
You also have the right to object to the processing of Your Personal Data on legitimate grounds (and to object to direct marketing without any need to prove legitimate grounds).
10. Unsubscribing from newsletter
Users may subscribe to a newsletter service on the Website, free of charge. The alert service provides updates on Homies’s projects, information on its products and the latest news.
If You change Your mind, You may unsubscribe from the alert service:
– by simply clicking on the link at the bottom of the Newsletter: , or
– by sending an email to firstname.lastname@example.org specifying the email address to unsubscribe.
11. Use of data in the event of a change in control
The Personal Data collected by Sleede may be transferred to third parties as part of a change in the control of the company, an acquisition, collective insolvency proceedings or a sale of the company’s assets.
12. Personal Data policy for children
Children are not the target audience of the Website. However, access to the Website is not restricted to adults, as the content posted is not unsuitable for under 18s.
The forms and questionnaires on the Website are not designed to collect information about children. If information is collected via the Website about a child, the child’s legal representative may contact Sleede's communications department to rectify, modify or erase that information (see the “Right to access, modify, rectify and erase data” section).
By using the Website, You agree to comply with the terms of this Confidentiality Policy.
In this respect, You are and will remain liable for any breach of this Confidentiality Policy and, in particular, for the confidentiality of Your login details for the Website and any unauthorised use of the Website.
To this end, You shall bear any financial penalty that may be awarded against Sleede, in particular by a French court (administrative or ordinary court) or any independent administrative authority, such as the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés – CNIL), based on any failure by You to fulfil Your obligations under this Confidentiality Policy.
Likewise, Sleede disclaims all liability in the following cases:
(i) intentional or unintentional use of all or part of Your Personal Data by a third party;
(ii) any provision of incorrect Personal Data or failure to update that data;
(iii) any failure to fulfil Your obligations under the Data Protection Regulations, this Confidentiality Policy or other contract documents enforceable against You.
14. New versions of the Confidentiality Policy
Sleede may amend the Confidentiality Policy and any updates may be implemented without prior notice by being posted online.
In such a case, the previous version of the Confidentiality Policy will be automatically terminated and superseded by the new version, which will be binding on and enforceable against all Users with immediate effect. Any use of the Website will be governed by the Confidentiality Policy in force at the time of that use.
Given the changes that may be made to the Confidentiality Policy, please consult the “Personal Data” section of the Website regularly.
15. Questions / Contact
Any questions or comments relating to this Confidentiality Policy or the manner in which Sleede collects and uses Your Personal Data should be emailed to email@example.com or posted to Sleede.
16. Entire agreement
If any clause of this Confidentiality Policy is invalid, in particular as a result of changes in applicable legislation or a decision issued by a court of law, this will not affect the validity of or the need to comply with the other clauses of this Confidentiality Policy, in any circumstances whatsoever.
17. Governing law and jurisdiction
This Confidentiality Policy is governed by French law.
Last update: January 29 2019