Privacy

PRIVACY CHARTER

Last updated date: April 22, 2021

We, THE HARMONIST, appreciate your interest in our products and services. THE HARMONIST recognizes the importance of your privacy. For the purposes of this Privacy Policy (the "Policy" or "the Charter"), the terms "THE HARMONIST", "we" "our" and "our" "refer to THE HARMONIST SARL and all of its subsidiaries and companies. affiliates. "You", "your" and "your" means you, as a user of our services, including websites, software applications and mobile applications, whether operated by us or on our behalf (the " Services ").

The purpose of this privacy policy is to formalize our commitment to respecting the privacy of users of the website www.theharmonist.eu (the “Site”) operated by THE HARMONIST SARL.

The Charter and the General Conditions of the Site form a contractual whole. All capitalized terms not defined in this Charter are defined in the General Conditions which can be consulted here: https://www.theharmonist.eu/policies/terms-of-service.

As part of the provision of our Site, we process your personal data in compliance with the General Data Protection Regulation 2016/679 of April 27, 2016 ("RGPD") and under the conditions set out below.

Personal data means any information relating to an identified or identifiable natural person. We collect and process personal data in the context of providing our Services or communicating about these Services exclusively, in strict compliance with the GDPR.

We only collect personal data that is adequate, relevant and limited to what is necessary for the purposes for which it is processed. Thus, you will never be asked to provide personal data considered "sensitive", such as your racial or ethnic origins, your political, philosophical or religious opinions.

By accessing THE HARMONIST websites and using the services provided, you consent to the collection and use of certain personal information described in more detail in this online privacy policy. It is important that you read this Policy along with any other privacy notices that we may provide on specific occasions when we collect or process your Personal Information so that you understand how and why we use your data. This policy supplements other notices and is not intended to override them.

If you refuse the terms of this Charter, please refrain from using the Site and the Services.

  1. In which cases and how do we collect your personal data and what data is collected?

THE HARMONIST collects certain personal information about you during your interactions with our Services. Personal information is information that identifies you or is directly or indirectly associated with you or your household, including, without limitation, identifiers such as your name, date of birth, time of birth, location of birth and contact information, such as your address, phone number, email address and business information such as your purchase data and order history. By visiting this website, THE HARMONIST will also identify your computer by its IP address which will be recorded, and collect certain information about your device, such as browser type and version, time zone setting, location, versions plug-in and operating system. IP addresses are collected primarily for the purposes of market research, system administration and aggregate reporting.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Information but is not considered Personal Information because such data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy statement.

We are likely to collect and store your personal data, in particular when you:

This includes the personal information you provide when you:

We use your personal data to enable the implementation and management of the Site Services and to respond to your specific requests. We also use your personal data for the purpose of operating and improving our Services, our Site and our approach.

If you have decided to receive emails and messages from us when creating your Account, then you will receive email and alphanumeric messages about our products and promotions. We will then use the personal data you provided when you registered. You can unsubscribe from these mailings at any time.

1.1 Site navigation

Connection data. Each time you connect to our Site, we collect personal data such as, in particular, your IP address and the MAC address of your computer, the date and time of connection, as well as information on the browser you are using.

Navigation data. We also collect information to identify how you access the Site, which pages are viewed and for how long. In this context, we may have recourse to the use of Cookies as specified below.

1.2 Creation of an Account

Access to some of our Services requires the prior creation of an Account. In accordance with the General Conditions, you will be asked to enter a certain amount of personal data when creating your Account, in particular your first and last names, your postal address, your email address and your telephone number.

1.3 Payment

Some of the Services available are chargeable. To this end, you agree that we may have recourse to external service providers who may collect personal data for the purpose of enabling the proper functioning of the services for processing payments by credit card or any other means of payment and , where applicable, delivery of products or services.

To pay for your purchase, you must provide your billing details as well as your payment details, and in particular your bank card number, expiry date, security code and the name of the card holder in the event of payment by Bank card.

You may also be asked to provide the name of your telecom operator, your mobile phone model and a valid mobile number so that you can provide purchase instructions directly through your mobile phone.

We keep the details of your payments, as well as the details of the purchases you make. The details of the transactions are kept either in our systems or with the external service provider. This retention is carried out for internal purposes, in particular for accounting, compliance and legal purposes.

1.4 Subscription to our Newsletter

You can give your prior consent to receive our newsletter regarding news, new products, services and promotions, as part of the Services.

You can also consent directly to the receipt of our newsletters by entering your email address in the places provided for this purpose on the Site.

In any event, you have the right to withdraw your consent to the receipt of such newsletters at any time and without charge.

1.5 Contacts

In order to respond to requests that you may make to our Customer Service and to confirm information concerning you, we may use your name, first name, e-mail address and telephone number.

1.6 Protection of children's privacy

If you are under 13, you are not authorized to provide us with personal information. If the parent or guardian of a child under the age of 13 believes that the child has provided us with personal information, that child's parent or guardian should contact us at the email below and request that these personal information is deleted from our files.

  1. Information We Collect When You Use Our Services

2.1 Automated technologies or interactions

As with most websites, we receive and store certain types of personal information whenever you interact with us online.

This information may include Internet Protocol (IP) addresses, browser type, Internet service provider (ISP), referring and exit pages, operating system, date stamp and date stamp. time and / or click stream data. When you access and use our Services from your mobile devices, we receive data from that mobile device.

This may include your device ID, location data, IP address, and device type. You can manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting the privacy and security settings on your mobile device.

Please consult the instructions provided by your wireless service provider or device manufacturer for how to adjust your settings.

2.2 Cookies: How do we use them?

2.2.1 What is a cookie?

A cookie is a text file that may be placed in a terminal when consulting an online service with browser software. A cookie file notably allows its issuer, during its validity period, to recognize the terminal concerned each time this terminal accesses digital content comprising cookies from the same issuer.

In any case, the cookies placed on your navigation terminal with your consent are destroyed 13 months after their deposit on your terminal.

2.2.2 What are the cookies issued on our Site for?

We use cookies to help us understand how users use the Services. For example, cookies collect information about the time you spend on a web page so that we can understand which web pages users are most interested in. If you prefer, you can choose to have your computer warn you each time a cookie is sent, or you can choose to turn off cookies by adjusting your browser settings.

The cookies we issue allow us:

When browsing the Site, social network cookies may be generated, in particular through the sharing buttons which collect personal data.

During your first visit to the Site, a cookies banner will appear on the home page. A clickable link allows you to find out more about the purpose and operation of cookies and refers to this Charter. Continuing to navigate to another page of the site or selecting an element of the Site (in particular: image, text, link, etc.) indicates your acceptance of the deposit of the cookies referred to on your computer.

2.2.3 How can you control the cookies used?

You can configure your browser software at any time so that cookies are saved in your terminal or, on the contrary, that they are rejected (either systematically or according to their issuer). You can also configure your browser software so that the acceptance or rejection of cookies is offered to you from time to time, before a cookie can be saved in your terminal.

Warning: any setting is likely to modify your Internet browsing and your conditions of access to certain services requiring the use of cookies. We decline all responsibility for the consequences of the degraded functioning of our services resulting from the inability to save or consult the cookies necessary for their operation and which you have refused or deleted. This would be the case if you tried to access our content or services which require you to identify yourself. This would also be the case when we (or our service providers) could not recognize, for technical compatibility purposes, the type of browser used by your terminal, its language and display settings or the country from which your terminal appears to be connected. to the Internet.

2.2.4 How to configure your navigation software?

For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to modify your preferences in terms of cookies. Below you will find information about the main browsers.

Internet Explorer / Edge

In Internet Explorer, click the Tools button, then Internet Options.

On the General tab, under Browsing history, click Settings.

Click the View Files button.

Firefox

Safari

Google chrome

For more information on cookies and on disabling cookies, you can consult the CNIL website.

  1. Information we collect from third parties

We collect personal information from various third parties, including those listed below. The collection, use and disclosure of personal information received from third parties are governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send you their own cookies and web beacons, and may collect information and use it in ways inconsistent with this Policy. A pixel tag is a small graphic contained on a web page, any document, or in an email. It allows the site owner or a third party to monitor website visits and appears to be invisible to visitors as web beacons are usually extremely small.

THE HARMONIST may include web beacons on this website to better monitor the effectiveness of the website or for any other lawful purpose. Clickstream information may include non-personal information such as the time and source of an individual visit, the type of browser used for that visit, the previous page, and any other non-personal information. Evaluating clickthrough information will help better understand how visitors visit this website, to identify preferred content, and so on. THE HARMONIST will collect information about the clickthrough flow of each visit to this website in order to better monitor the effectiveness of the website or for other legitimate purposes. Please carefully review these third party privacy policies to understand how your information may be collected, used and disclosed by these third parties.

3.1 Third party service providers

We collect personal information from service providers, including when we operate accounts on third party platforms, such as

online request submission and management platforms,

student information platforms,

learning management platforms,

email platforms and

social media platforms.

3.2 Third-party advertising partners

We collect Personal Data received from third party advertising partners, including partners who host and manage various advertisements and online forms where you can request additional information.

3.3 Google Analytics

We use third-party cookies provided by Google Analytics to help us better understand visitors to our website. These cookies collect IP address and usage data, such as the time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our. website. Based on this information, Google Analytics compiles aggregated data about website traffic and interactions, which we use to provide better experiences and tools for users in the future. To learn more about Google Analytics, visit https://support.google.com/analytics.

3.4 Third-party cookies

We may use third party service providers, including Google, Facebook, and Instagram, to serve you ads about our products and services when you browse the Internet. These third-party vendors may use their own cookie labels to track your online activities and purchases in order to serve targeted advertising based on your interests. You can learn more about Google's advertising cookies and opt-out options by visiting http://www.google.com/policies/technologies/types/

You can learn more about Facebook's advertising cookies and opt-out options by visiting https://www.facebook.com/p

You can learn more about Instagram advertising cookies and opt-out options by visiting https://help.instagram.com/1896641480634370?ref=ig.

3.5 Your "Private Navigation / Do Not Track (DNT)" browser setting.

Some web browsers have a "Do Not Track" feature that tells websites you visit that you do not want your online activity to be tracked. Many websites and applications, including the Services, are not currently responding to DNT signals from the web browser because these signals are not yet consistent. For more information on DNT signals, please visit http://allaboutdnt.com. Other third-party sites may track your browsing activity when providing content to you, allowing them to personalize what they present to you on their websites.

  1. How do we protect your personal data?

THE HARMONIST uses reasonable care to store and retain personal information and to protect it against alteration, misuse, loss or destruction. This includes storing personal information on servers protected by a firewall and ensuring that all transmissions to third parties use secure transmission technology.

Internal access to personal information will be limited to those individuals who need to have access to the personal information in order to provide or maintain or offer products and / or services. There are a limited number of people with access to personal information and they agree to abide by THE HARMONIST's privacy and security policies.

We have implemented technical and organizational security measures in order to guarantee the security, integrity and confidentiality of all your personal data, in order to prevent them from being distorted, damaged or that third parties not authorized access. We ensure an appropriate level of security, taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the processing as well as the risks and their likelihood.

However, it is specified that since no security measure is infallible, we are not able to guarantee absolute security to your personal data.

No data transmission over the Internet can be guaranteed to be absolutely secure. Therefore, while THE HARMONIST strives to protect personal information, the security of any information that you transmit to THE HARMONIST or that you may receive from THE HARMONIST cannot be guaranteed.

In addition, you are responsible for ensuring the confidentiality of the password allowing you to access your Account. Do not share this information with anyone. If you share your computer, remember to log out before leaving a Service.

  1. How do we use your personal information?

Our primary purpose for collecting personal information is to provide you with the products and services you request.

We may also use your personal information for the following purposes:

  1. When do we share your personal data?

6.1 Sharing your personal data with third-party companies

THE HARMONIST may, without notice, share personal information with its affiliates and with other third parties who provide services on behalf of THE HARMONIST for the sole purpose of providing you with valuable information and / or services, as discussed in this Charter.

In addition, THE HARMONIST may share personal information with third parties who provide marketing and other services on behalf of THE HARMONIST, or to comply with certain legal requirements, as discussed below. THE HARMONIST may also share personal information with unaffiliated parties with whom THE HARMONIST may have joint marketing agreements.

However, such third party will not be permitted to sell, rent, trade or otherwise use your personal information.

While browsing the Site, your personal data may be transmitted to external providers who provide a service. These third parties provide a service on our behalf for the purpose of enabling the proper functioning of credit card payments and other Services.

The Services may include links and plug-ins to websites operated by third parties such as Twitter, Facebook and Instagram buttons (“Third Party Sites”). THE HARMONIST does not control any Third-Party Site and is not responsible for the information it may collect. A third-party site's information collection practices are governed by its privacy policy. It is your choice to access any third-party site. We recommend that you read its privacy policy if you choose to do so.

Personal data may be transferred to countries outside the European Union.

In accordance with the GDPR, all transfers of personal data to a country located outside the European Union and / or not offering a level of protection considered sufficient by the European Commission have been subject to cross-border flow agreements. in accordance with the standard contractual clauses issued by the European Commission.

Other transfers of personal data to the United States are governed by the E.U. - U.S. PRIVACY SHIELD. : Click here for more information.

Except in the case where a third party asks you to accept a confidentiality charter and conditions of use which are specific to it, the third companies having received communication of your personal data have undertaken to process your personal data only. for the implementation of our Services.

6.2 Sharing with authorities

We may be required to disclose your personal data to administrative or judicial authorities when:

  1. their disclosure is necessary for the identification, arrest or prosecution of any individual likely to prejudice our rights, any other user or a third party.
  1. We may be legally required to disclose your personal data and cannot object to it if we are required to do so under a law, regulation or legal process, such as a subpoena. appear;

iii. In response to requests from government entities, such as law enforcement agencies;

  1. When we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) as part of an investigation of suspected or actual illegal activity.

6.3 Information you ask us to share

You may be presented with an option on our Service to have us send certain information to third parties or give them access to it.

If you choose to do so, your personal information and other information may be disclosed to such third parties and any information you disclose will be subject to the privacy policies and practices of such third parties.

6.4 Service providers

We may use third party service providers to perform certain business services on our behalf or for the Service and may disclose Personal Information to service providers as they require to perform those business services.

Service providers are only permitted to use, disclose or retain personal information to provide these services and the sale of personal information is prohibited. Business services provided include, but are not limited to, hosting services, software as a service, document management services, communication services such as email, text messaging and messaging services. chat, software and website development services, collection services, accounting and auditing services, compliance services, quality control services, analysis services, call center services, housing services, marketing services, employment services and employment verification services.

6.5 Internal third parties.

We may share Personal Information with our parent company, subsidiaries and other companies owned or controlled by THE HARMONIST who may use Personal Information for the purposes described above.

6.6 Commercial transactions

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Otherwise, we may seek to acquire other businesses or merge with them. If there is a change in our business, the new owners may use your personal information in the same way as described in this policy.

6.7 User disclosures

Certain personal information is systematically disclosed as a result of your use of certain services. Any personal information shared on a public forum using the Services or on another website (such as Facebook, Google, LinkedIn, Instagram or Twitter) may become public. We cannot control the use of information disclosed in these public forums. You should exercise caution when disclosing information in these public areas, especially your health information and location data, and be careful about how you disclose your personal information. Content posted in public areas of the Services, including advice and opinions, represents the views and is the responsibility of those who post the content. We do not endorse, endorse, review or endorse the posted content. If you have any questions or comments about any content posted using the Services, please contact us at the address below.

6.8 Sales of personal information.

Non-personal and aggregated information.

THE HARMONIST uses aggregated data to improve the design of this website and may share it with marketing and advertising agencies for this purpose. All this information can be collected through cookies, web beacons, click flow information as indicated above.

  1. How long do we keep your personal data?

We will only keep your personal data for as long as you register on the Site in order to ensure your identification when you connect to your Account and to allow the provision of the Services.

Thus, if you unsubscribe from the Site, your personal data will be erased and only kept in the form of an archive for the purposes of establishing proof of a right or a contract.

In any case, we will keep your personal data for a period not exceeding that necessary for the purposes for which they are processed in accordance with the uses set out in this Charter and in compliance with laws and regulations.

  1. UPDATING YOUR INFORMATION

You can update or correct the personal information we have collected at any time; so that we can update our records, simply email us with your updated information at support@theharmonist.com.

  1. INFORMATION BY E-MAIL

In the event that you provide your email address, we will include you on our mailing list. If you are currently on this list and would prefer to be removed and not receive further information from us, simply email us at support@theharmonist.com and we will remove you from this list.

  1. UNSUBSCRIBE

If you would prefer that THE HARMONIST no longer use the personal information you have provided, please contact us at support@theharmonist.com.

  1. What are your rights?

11.1 General provisions

You are the only ones who have communicated the data in our possession to us through the Site. You have rights over your personal data. In accordance with the regulations on the protection of personal data, in particular Articles 15 to 22 of the GDPR, and after having provided proof of your identity, you have the right to ask us for access to personal data concerning you, rectification or erasure thereof.

In addition, you can us

- Ask to update or correct personal information if it is inaccurate.

- Request that we delete your personal information

- Refuse to share your personal information with third parties for certain purposes, including sharing which may be defined as a sale under applicable laws.

You can unsubscribe from our newsletter at any time by sending a message to the following address support@theharmonist.com or by clicking on the unsubscribe link in the emails you will receive from us.

In addition, within the limits set by law, you also have the right to oppose the processing, to limit it, to decide the post-mortem fate of your data, to withdraw your consent at any time and the right to portability. personal data provided.

You can contact our Services in order to exercise your rights at the following e-mail address: support@theharmonist.com or at the following postal address: The Harmonist 36 avenue George V, 75008 Paris, by attaching to your request a copy of an identity document.

These rights vary depending on where you reside. However, we will make reasonable efforts to honor your request, even if your country or state does not require us to do so. If you ask us to delete or stop using your personal information, we may not be able to honor that request if the information is necessary to process your payments or returns, fulfill your order or comply with tax requirements, audit or regulatory.

Please contact us at support@theharmonist.com if you wish to obtain personal information.

11.2 Rights Under California Privacy Laws

California Civil Code Section 1798.83 allows residents of California who have provided personally identifiable information to us or our advertisers and third-party marketing partners, as applicable, to request certain information regarding our disclosure of information personally. identifiable to third parties for direct marketing purposes. Please contact us at support@theharmonist.com if you would like to inquire about possible sharing of your personal information. We will provide you with the requested information via email to your email address used to make such a request.

  1. Can we change the Charter?

We reserve the right to modify or supplement the Charter at any time. It is therefore recommended that you consult it regularly. If there are any changes, we will post those changes on this page and in such places as we deem appropriate based on the purpose and significance of the changes made.

Your continued access to this website will be considered acceptance of any amendment or supplement.

Therefore, we encourage you to review our online privacy each time you visit this website for the most recent version.

If you do not accept certain substantial modifications made to this Charter, you must stop using the Site.

  1. CONTACT DETAILS

If you have any questions about THE HARMONIST and this policy, you can email us at support@theharmonist.com.