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DATA PROTECTION CHARTER OF PERSONAL DATA AND COOKIE MANAGEMENT

The herewith personal data protection charter and cookie administration defines PHA’s – CLAUDE MICHY’s policy with regard to privacy protection when dealing with personal data and cookies.

It applies to data on the ​gpfrancemoto.com website​.
In order to facilitate access to this charter you can consult the file on our website welcome page and

all the pages where personal data is requested.
The herewith charter is designed to inform you on the following:

• about the means we use to gather your personal details, maintaining the strictest respect of your rights.
• about the details submitted on our website.
• about how we use these details and your rights concerning these details.The PHA company therefore clarifies by the herewith charter and/or every time your personal data is requested at the end of a payment process along with all other methods of payment operations (data gathering, recording, modification …).The PHA company is committed to:

• ensure the respect of the personal data protection
• inform all persons of the existence of their access, rectification and opposition rights.
• proceed to the completion of all formalities whether legal or regulatory.We inform by the herewith charter that we agree to the conformity of the gathering and administration of your personal details according to the data processing law n°78 – 17 of January 6th 1978, amended and in its current version, to deal with computer files and individual freedoms, along with the general regulations and the data protection laws as well as the resulting laws and regulations adopted by the European parliament on the 27th April 2016.I.DATA PROTECTION:

1) Definition and essence of personal data

When using our website or connected via our website, we can gather personal details when submitted to us by the following:

Information files, creation of a customer’s account, orders placed, subscription to our newsletter.
When we are using the term ‘personal data’ we mean all the data that allows us to identify, directly or indirectly, the customer (by gathering information) such as names, aliases, date of birth, photographs, phone numbers, profession, training courses, diplomas, career and professional experience, details relative to your website transactions, details of your purchases and subscriptions.

2) Access rights, rectification, suppression, portability and opposition of data processing.

According to the law passed on January 6th 1978 “data processing and freedom” along with the General Data Protection Regulation provisions, adopted on April 27th by the European Parliament allowing you access, rectification, suppression, portability, and opposition of data processing of personal data rights.

Equally, you have the possibility of opposing any data processing should it be used for commercial reasons.

You can exercise your right of access to your data and rectify it by contacting:

PHA
15 bis, PLACE RENOUX
63000 CLERMONT FERRAND
OR
e-mail to ​contact@pha-michy.com

In order to do this, we ask you to write to us at the above address or send an e-mail, your signature is necessary accompanied by ID justification details, (ID card or passport) which shows the signature of the person wishing to exercise his/her right.

3) Management of the personal data by the PHA company
3.1 Data collection means
When browsing on the gpfrancemoto.com website, in order to access the services offered, we are allowed to collect your personal data. Before any personal data is registered, we acquire your consent for this via the completed electronic form filled in by yourself with a tick beside the clause stating that you are fully aware of and agree to the herewith data protection charter conditions.

3.2 The Purpose of Data Collection

Your personal data is collected and kept for the following reasons to:

• Send newsletters and promotional sales, thus keeping you up to date with all latestinformation;
• Administrate your subscriptions and cancellations of these when necessary as well as thesatisfaction of our service surveys.
• Elaborate reports and commercial statistics, marketing studies and conduct, with the aim ofimproving our services and meet your expectations by offering products adapted to yourneeds.
• Create a client base and hence making the online ordering process easier for, theadministration of these orders, raising invoices and ensuring good delivery services.
• Manage your orders and the follow up of the customer relationship, notably regarding yourpossible complaints and questions.
• Administrate your access rights, rectification and opposition of your data.
• Keep data in legal documents in compliance with the accountancy rules for a statutoryduration so that we can answer all fiscal demands and social organisations if and when necessary.

We commit ourselves to collect only data when strictly necessary for all orders requested so that we can deal with them in the best possible manner and hence offer you our best services available as stated on the internet.

Your data can be used for all the events organised by the PHA company.

3.3 Data Conservation

The personal data collected is kept for a specific duration that does not exceed the legal duration for the reason for which they had been received. In any case the said duration cannot exceed 5 years after the termination of the commercial relationship whether it be with customers or sponsors and 5 years from the last contact for potential customers, in both cases solely for marketing purposes.

When we no longer have no more reasons to keep the collected data:

• We are committed to make contact with the customers to establish whether or not they wishto continue the reception of our newsletters and promotional information.
• Failing that, the data will be archived, anonymised or destroyed;
• At any time the customer can oppose the personal data processing on exercising his/heraccess, rectification, suppression and opposition rights as stated in previous clauses.3.4 Data DestinationThe personal data collected is for PHA’s use only.
  In order to give a satisfactory service as stated herewith, the authorised PHA office staff also has access to your personal data and is duly entitled to use it when required.The personal data submitted to us will not be transferred to a country/destination outside of the European Union. However, should it be necessary to submit data to a company located in a foreign country and in particular outside of the European Union we will personally commit ourselves that all the necessary measures are put in place to ensure the safeguard of personal data with all the high security protection standards by:

• Making sure that the countries are considered safe and can offer a high security safeguard for data.
• Requesting all necessary authorisations with the local Control Authorities before data collection if this is requested and according to the country involved.
• Acquiring all the security guarantees and confidentiality measures from the stated authorities by imposing strict confidentiality clauses enabling us to make regular controls and audits.

3) Collected personal data security and confidentiality

The security and confidentiality of your personal data given are our priority.
We strive to ensure that all the technical and useful organisational measures are in place for the safeguard of personal data that you have submitted and the risks involved when processing them. This is in order to maintain the security of his/her personal data and thus not allowing it to be deformed, destroyed or damaged or that a third party can obtain illegal access to data.

To maintain these security measures, we have put in place the following technical procedures to:

• Raise user awareness so that he/she understands all the security and privacy issues.
• Authenticate the users: recognise them so they can obtain the necessary access.
• Administrate the authorisations: limit access to data that is only needed by the user.
• Secure the company workforce: prevent fraudulent access, viruses or remote access by an outside user, notably via the internet.
• Protect the intranet: only authorise the necessary network functions for on site processing;
• Secure the server: reinforce the security measures needed for the server.
• Secure the website: ensure that the minimum acceptable methods are used on the website.
• Secure the mobile electronic processing chain: anticipation with security measures againstdata hacking, theft or loss of portable equipment along with organisational measures such as electronic ID and passwords.The security and confidentiality of personal data also relies upon the individual user. We therefore advise he/she not to communicate their data ID or password to anyone, also systematically disconnect themselves from their profile and client account (notably in the case of linked accounts), close every window after terminating each session, in particular if he/she shares a computer for internet access and never record their ID and password on the browser. By following these instructions he/she will avoid other users obtaining access to his/her personal data.

II.COOKIE POLICIES AND MANAGEMENT

The term “cookies” groups all tracers deposited during an internet consultation; reading of an e-mail software utilisation or a mobile application. It is a text file that one visits and is registered on the hard drive or the browser memory. A cookie enables your computer to stock various technical data which allowing to control the general public access to our websites (number of visits, frequency of exposure to a publicity banner, connection to other websites …) or the personalisation of the pages shown for your next interaction on the site.

When browsing on our Website the information relative to your browsing may be registered in the “cookie” files which are already installed on your computer, tablets or smartphone.
Cookies are necessary for the good operations of a website. They are used to keep certain information and maintain a secured connection system, collect statistics with the view to optimising the site functions and adapting the contents to your centre of interest.

So when one visits our website for the first time and the cookies can be installed on your computer, we will inform you cookies are used by the website, this is by a window that will appear on the page you are looking at. In terms of this information, you can have access to the Charter herewith, allowing you to accept or refuse the cookies. We would like to bring to your attention that by continuing to browse on our website whilst the window appears you automatically accept the cookie utilisation on our website. You can however at any time modify the relative cookie parametres as they are exposed herewith.

1) Types of Cookies

There are different types of cookies which allow you to have access, as soon as you have accepted them, to a certain number of functionalities.

Ø Cookies given out by the PHA company on its website:
These are cookies submitted by PHA on your computer, tablet or smartphone when browsing its website.
When you browse its website, your computer is connected to the server which will give all the resources requested by automatically recording each operation in a specific file in which your computer can be identified by its IP address. Your browser will automatically transfer certain standard data: with your IP address, it is about the type of browser you are using along with its functionality, the explorer systems, identification of a third party such as Facebook, Twitter …and those with whom you have been connected with the dates and times of access to PHa4S WEBSITE;
This data and in particular the IP address does not allow us to nominatively identify you.

The cookies that PHA emit allow them to:

• Keep an eye on the general website activity, to see mistakes and watch if the website benefitsfrom all the material resources adapted to it.
• Establish statistics and frequency and usage volume of different elements of the website.
• Adapt the website with a dynamic display of one’s device (language used, exploitationsystem)
• Facilitate the use of PHA website and thus avoid having to fill in data at every visit, orpersonalising of their content according to the preferences and interests shown in previousvisits.
• Improve the navigation ergonomics and globally identify the interests of the web user.

One is free to accept or refuse these cookies. All one has to do is modify certain navigation parametres by refusing the cookies or by being warned that there could be a cookie recording on the computer. One can also erase the cookie stocked on the computer, hence deleting all information in stock.

Cookies emitted by a third party.
– The emission and utilisation of the said cookies by a third party are subject to the privacy

protection policies of a third party. We inform you herewith of the object of the cookies of which we are aware and the means that are at your disposal enabling you to make choices of the cookies.

Audience measurement cookies:
We use Google analytics to collect the information about the utilisation that you have for our website, so that:

• To help you measure and study the efficiency of our website contents
• To follow the analytic data on our website and the utilisation made by the users
• To improve the service of our websitesGoogle analytics collects the information on the pages you have visited and the amount of time you have spent on this. We do not collect or share your personal data, nor do we authorise the utilisation of your data.
  You can specify in the parametres that you do not wish to send the information to Google Analytics. You can at any moment inform yourself and parametrer your cookies in order to accept or refuse them on Preferences Administration on the cookies. You can indicate your preference either globally on the website or service by service.

2) Cookies stock duration

In accordance with the rules in place, the cookies that are collected on our website cannot be kept more that 13 months maximum.

3) Manage cookies preferences

You have several means of managing cookies. Your navigator can equally be configured to advise you on the cookies which are on your computer, tablet or smartphone and you will be asked if you want to accept them or not. You have the right to refuse the cookies one by one or systematically. Nevertheless, we would like to draw your attention to the fact that all parametre modification you undertake could vary your navigation on the internet and thus necessitating use of the cookies. A parametre modification could therefore block your access to certain processing on our Website. At any time you can make the choice to amend your wishes regarding cookies by following the procedures mentioned herewith.

Every navigator has a different configuration. The modification methods to follow are written on your navigator’s helpline, these will help you to know how to change your wishes when dealing with cookies.
You can deactivate the cookies by following the instructions below

●  Internet explorer https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cooki es

●  Safari​ https://support.apple.com/fr-fr/HT201265

●  Chrome​ https://support.google.com/chrome/answer/95647?hl=fr

●  Firefox

https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences?redirectlocale=fr&redir ectslug=activer-desactiver-cookies

For the other navigators: please consult the documentation provided of your online helpline files.

3) CHARTER UPDATE

We have the right to partially or completely modify the herewith charter at any time taking into consideration the necessary changes for our own use, the evolution of our use and the staff processing needs. The latter will always conform with the French and European, internet legislation and rules. We ask therefore to regularly consult the herewith charter especially before entering any new data collection to acquire a better understanding and utilisation of your personal data. We have the authority to ask you at regular intervals, to validate the recognition of the herewith charter.

The latest data update of the herewith charter was 01/08/2018.

It is potentially possible to find a link between the legal wording and the tab “Data protection and cookie management”