- Collect and process the personal data of the User, in accordance with the French Data Protection Act no. 78-17 of 6 January 1978, as amended by the Law of 20 June 2018 and the Ordinance n° 2018-1125 of December 18, 2018, relating to personal data protection, and Regulation no. 2016-679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free circulation of such data (hereinafter the "Regulations");
- View, process and store information relating to the User's browsing of the Website, which may be recorded using “Cookies” (hereinafter "Cookies").
The data controller of the personal data is SUEZ, a limited company (société anonyme) registered with the Nanterre Trade and Companies Register under number 433 466 570, having its head office at Tour CB 21, 16, place de l’Iris, 92040 Paris La Défense, France (hereinafter the "Publisher").
The Publisher may amend the Policy at any time, in particular in order to comply with any regulatory, case law, editorial or technical developments. Before browsing the Website, the User must read the latest version of the Policy.
I. Personal data protection
While the User is using the Website, the Publisher may collect and process personal data so that the User can access the services offered by the Website (hereinafter the "Services"). For each form, the Publisher undertakes to limit the collection of data to what is strictly necessary (data minimisation principle).
1) Which data is collected?
- Contact Data: this is the mandatory data that the User enters when creating an account on the Website and/or filling in the contact form and/or reporting an abusive comment via the dedicated form, namely: surname, first name, email address.
- Data voluntarily disclosed by the User: refers to the personal information that the User voluntarily discloses to the Publisher by filling in the free text fields provided (i) in the contact form, namely "Your request" and/or (ii) in his profile sheet, namely “Title”, "Position", "Organization", "City", "Country" and "Summary", or by uploading a profile photo to his account and/or (iii) in the abusive comment form, e.g., "Why are you reporting this comment? " or in the "Comments" fields associated with the various content on the Website. The Publisher does not require personal data to be entered in these free text fields and strongly advises the User to avoid disclosing personal data that he does not wish to make public, or any personal data of third parties without having obtained the prior and detailed consent of said third party (also authorising the Publisher to publish said third party personal data via the Website). In particular, the User is free to decide whether to upload a photo to his profile, and if he does so, he accepts that his photo will then be visible to all Users of the Website (regardless of whether they are members of the Website), except where he has chosen the option "anonymous profile" in the account settings options. In any event, SUEZ shall endeavour to use only data that is strictly necessary for using the services on the Website or for processing the User's request (hereinafter "Published Data"). If the User decides to voluntarily disclose specific data about him (such as his ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union, physical or mental health, sexual orientation or criminal record) he acknowledges that he has chosen to publish such data on his profile and that it will be visible to other users. The User acknowledges and accepts that he should only publish personal data on his profile that he agrees to make public.
- Browsing data: data that the Publisher collects while the User is browsing the Website such as the date, logging on and/or browsing time, type of browser, browser language and his IP address.
All this data will be referred to collectively hereinafter as the "Data".
2) Why does the Publisher collect the User's Data?
The data collected in connection with the use of the Website is processed with the following objectives:
- Management of the community: managing User registrations and profiles when setting up their accounts; managing User contributions and comments;
- Customisation of the platform's home page to match the User's interests;
- Managing User participation in Challenges;
- Handling questions and requests sent by Users via forms;
- Dealing with inappropriate or illicit comments reported via forms;
- Compiling statistics and measurements on the use of the Services (via Cookies)
When collecting the Data, the User is informed if certain Data must be necessarily filled in or if they are optional. Data identified with an asterisk in the contact form is mandatory. In the absence of information of mandatory sections, access to the Services and their use by the User may be restricted.
The User consents to enter into the contract by filling in the account registration form, by sending his request for information or his report using the contact and abusive comment forms provided for this purpose, and by providing his contact details. The Publisher performs the contract by granting access to the collaborative features and/or responding to the User's request by sending him the information by email. This performance of the contract entails knowing the identity of the User and being able to interact with him. The Publisher may also process certain Data where there is a legitimate interest (in particular to guarantee the Website's security) or with the express consent of the User (if the Publisher expressly mentions it on the form).
3) Recipients of the Data collected
When a User creates an account and becomes a member of the Website, the Data that he has entered on his profile is made visible to all Users of the Website (regardless of whether they are members of the Website).
The Publisher shall take all necessary precautions and appropriate organisational and technical measures to safeguard the security, integrity and confidentiality of the data and, in particular, to prevent it being distorted or damaged or accessed by unauthorised parties.
- Data transferred to public authorities and/or bodies:
In accordance with the Regulations in force, the Data may be sent to the competent authorities on request and in particular to public bodies solely to comply with legal obligations, officers of the courts, members of the legal profession and the bodies responsible for debt collections, and in connection with the pursuit of perpetrators of offences committed on the Internet.
- Data transferred to third parties:
The Data may, in accordance with the above provisions, be used by the Publisher, its subcontractors, its affiliates:
- The Publisher's personnel, the departments responsible for audits (Internal audit Department in particular) and the Publisher's sub-contractors (such as SUEZ's IT and/or technical services providers) will have access to the Data collected in connection with the use of the Website;
- By confirming the Website's connection banner, the User accepts that the Data relating to their browsing may be used for the purposes of (i) offering services tailored to the user's centres of interests such as are indicated by his browsing, (ii) compiling browsing statistics and Website audience figures and (iii) carrying out studies with a view to optimising the Website's ergonomics.
4) User's Access to Personal Data
In accordance with the Regulations, any natural person has the right to request access to their personal data, correction and erasure of their personal data, restriction of processing, and transfer of their personal Data, and to issue general and specific instructions as to the manner in which the User wants these rights to be exercised after his death.
These rights may be exercised at any time, subject to sending proof of identity:
SUEZ, Brand and Digital Department, Digital Communication Unit, Tour CB21, 16 place de l’Iris, 92040 Paris La Défense Cedex
By email: firstname.lastname@example.org
If you have an issue with the management of your personal data by the Publisher, you can contact SUEZ's Data Protection Officer (Email: email@example.com) or send a complaint to the competent protection authority (in France, the CNIL, at 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07).
The Publisher recalls that any natural person may, for legitimate reasons, object to the processing his Data.
5) Data storage and archiving period
Users' data will not be kept beyond the time strictly necessary for the ends pursued, as described herein, in accordance with the Regulations and the applicable laws. In this regard, Data collected in order to manage requests for information or Users' reports will be kept for the period necessary for the processing of the request or report, and subsequently in intermediate archiving for three years. Contact Data of the User will be kept for as long as his account remains active. After the account has been closed, the Data will be kept in intermediate archiving for three years. However the Data may be archived beyond the expected retention periods for the purposes of research, observation and the prosecution of criminal offences so that, as and when necessary, this Data can be made available to the judicial authorities or to defend itself against possible legal action. User’s data will be deleted after expiration of the retention periods.
In addition, the Publisher may keep Data on a definitively anonymous basis for producing statistical analysis. Under no circumstances shall these studies make it possible to identify the users, and they shall relate only to trends derived from their aggregated Data.
The Publisher shall take appropriate technical and organisational measures to ensure that the Data is secure and to prevent unauthorised access or disclosure of the User's data. However, the Publisher cannot guarantee that all risks of hacking, alteration, unlawful reproduction or misuse of Data have been eliminated.
A Cookie is a text file that can be saved on a device when viewing a Service with a browsing application, via the Website. A Cookie enables its issuer, during its validity period, to recognize the device concerned each time this device accesses digital content with Cookies with the same issuer and, depending on the Cookie, to collect additional information anonymously on the behaviour of the User within the Services.
The User is informed that when he logs on to on the Website to use the Services, Cookies are installed on his receiving device (computer, tablet, smartphone, etc.) to ensure that the Services work properly, or on his browser, depending on the choice expressed by the User with regard to Cookies. This choice can be changed at any time.
The Cookies we use:
Name of cookie Description of cookie
- F5_ST: session management cookie
- LastMRH_: session management cookie
- MRHSession: session management cookie
- TS01cb58f2: session management cookie
- JSESSIONID: technical cookie
- LFR_SESSION_STATE_20120: technical cookie
- GUEST_LANGUAGE_ID: choice of language cookie
- COOKIE_SUPPORT: technical cookie indicating whether cookies are supported
- CookiesFacebookEnabled: cookie authorising the use of Facebook cookies
- CookiesGoogleAnalyticsEnabled: cookie authorising the use of Google Analytics cookies
- CookiesLinkedInEnabled: cookie authorising the use of LinkedIn cookies
- CookiesTwitterEnabled: cookie authorising the use of Twitter cookies
- CookiesYouTubeEnabled: cookie authorising the use of YouTube cookies
The Website also uses Google Analytics to manage statistics.
The Google Analytics service records visitor numbers and identifies the way in which they use the Website. These Cookies are placed and read on the User's device as soon as he accesses a Website that uses the "Google Analytics" service.
The data generated by these Cookies concerns:
- your use of the Website;
- your IP address in order to determine the city where the connection originates. This data is made immediately anonymous after localisation and is not disclosed to the Publisher.
You can obtain more information on the Google Analytics service by visiting the page http://www.google.com/analytics/learn/privacy.html.
1) What are Cookies for?
a) Browsing Cookies
Browsing Cookies help to improve the performance of the Services in order to provide the User with optimum use of the Website. These Cookies do not require the notification and agreement of the User before they are placed on the User's device. More specifically, these Browsing Cookies make it possible to:
- draw up traffic and usage statistics and volumes for the various components of the Website (sections and content visited, browsing path) to enable us to improve the interest and ergonomics of our services;
- adapt the Website presentation to the display preferences of your system (language, display resolution, operating system used etc.) during visits to our Website, depending on the viewing and reading hardware and software on your device;
- implement security measures, for example when you are asked to log on again to access content or a service after a given period of time.
b) Behavioural analysis and audience measurement Cookies:
Behavioural analysis and audience measurement Cookies are used for compiling statistical measurements of Users' browsing data, to count the number of visits, the number of page views, the User's activity on the Website and his rate of return visits. These Cookies also identify which information on the Website may be of most interest to the User, in order to adapt the Website to the User and improve his browsing experience, and the relevance of the messages that may be sent to the User if he has previously agreed to this option.
c) Third party social networks share Cookies:
d) Flash© Cookies on Adobe Flash Player™:
Adobe Flash Player™ is a computer application that permits rapid development of dynamic content using the Flash computer language. Flash (and similar applications) stores the settings, preferences, and use of this content using technology similar to that of Cookies. However, Flash Player manages this information and the User's preferences via an interface that is different from that provided by his browser. Provided that the User's device is able to view content developed using Flash, the User can access his Flash Cookies management tools directly via the website http://www.adobe.com/fr/
2) How can Users manage Cookies?
The User is presumed to have given his agreement:
- by clicking on the "OK" button that appears on the information banner visible when he first logs on to the Website;
by continuing to browse, i.e., the user clicks on an element of the Website (an image, link or "Search" button, etc.) or visits another page on the Website;
If the User agrees to Cookies being saved to his device, the Cookies embedded in the pages and content that he views may be stored temporarily in a dedicated space on its device. They can only be read by their issuer. The agreement given by the User is only valid for thirteen (13) months from the date on which the Cookies were first placed on the User's device, following the User's granting of consent.
If the User refuses to accept Cookies on his device or in his browser, or if he deletes the Cookies saved there, the User is informed that his browsing and his experience on the Website may be limited. This may also be the case if the Publisher or one of its service providers is unable to recognise, for the purposes of technical compatibility, the type of browser used by the device, the language settings and display or the country from which the device appears to be connected to the internet. Where applicable, the Publisher disclaims all liability for consequences relating to the reduced operation of services resulting (i) from the User's refusal of Cookies and (ii) the fact that the Publisher is unable to save or to read the Cookies necessary for their operation as a result of the User's preferences.
The User can configure his browser in such a way that the Cookies are saved on the device or rejected, either systematically or depending on who issued them. The User can also configure his browser so that it offers him the option of accepting or refusing Cookies on an ad hoc basis, before a Cookie is saved on his device. Browsers differ as regards managing Cookies and User preferences. These are described in the browser's Help menu, which will inform the User how to change his Cookie preferences:
For Internet Explorer™:
For all other browsers, please consult the Cookie management help pages available on the internet.
Users can choose to express and change their wishes as regards Cookies at any time.