"COFFEE BREAK" Personal Data Policy PHMC GPE LLC, COFFEE BREAK's publishing company, undertakes, as part of its business activities and in accordance with the legislation in force in France and Europe, to ensure the privacy, confidentiality and security of the personal data of the users of its services, as well as to respect their privacy. This Personal Data Policy defines the principles for the processing of the personal data that COFFEE BREAK collects from you, and which you provide to COFFEE BREAK on the registration page or that you yourself provide to our business partners.
We invite you to read this Personal Data Policy carefully to understand COFFEE BREAK's practices concerning the processing of your personal data.
By using this application and/or by using the services offered by COFFEE BREAK, you acknowledge having read the provisions of this Personal Data Policy (hereinafter the "Charter"), and you authorize us to collect, use and transfer your Personal Data and your User Data in accordance with these provisions. If you do not accept the terms of this Charter, you can decide not to use this application, and you must not communicate Personal Data on this application. This Charter forms an integral part of the Terms and Conditions of Use of the COFFEE BREAK Website. It is governed by the laws of Delaware and must be interpreted in accordance with these laws. You agree to bring any dispute arising on the occasion of the use of this Website before the Court of Chancery of Delaware.
Article 1 – DEFINITIONS
"Consent": means the agreement of a user to add their email address to a Mailing List to receive email messages or emails from COFFEE BREAK and/or its partners. Consent is collected by a legal mechanism located on the registration page which states the disclaimer "By using this service, you agree to receive free helpful tips by email from the company and its partners. You have a right of access, modification, objection and deletion of this information .
"Personal data": data directly or indirectly allowing the identification of the individuals to whom it applies, whose processing is carried out in any form whatsoever, by a natural person or a legal entity.
"Opt in": personal data is designated opt-in that can be used by the entity that has collected it in order to send promotional or commercial messages to the person concerned.
Article 2 - COLLECTION OF PERSONAL DATA
COFFEE BREAK's business activities require the submission of certain personalized information. The procedures for collecting and processing your personal data should accordingly respect certain fundamental rights in a spirit of loyalty and transparency. The information collected includes your name, business name, title, address, telephone and/or fax number or email address and other similar information that you may submit when you send comments, ask questions or request information from COFFEE BREAK, or after you have registered on the Website or have completed your user profile. This request for information is completely optional and you have the option to refuse to provide such information. However, in this case, COFFEE BREAK will not be able to respond to your request, or receive or process your registration on the Website or your user profile.
Your personal data is collected:
• When you register on the Website,
• When you make contact or communicate with us,
• When you use or are billed for fee-based services,
• When you agree to voluntarily participate in advertising activities or accept to subscribe to the Newsletter.
In case of dispute, COFFEE BREAK is also required to collect, as part of its management and for the proper use of its internet Website, the following impersonal data:
• IP addresses with an indication of the time,
• Cookies, local Flash data,
• The type of browser, the operating system, the destination URL that directed you to our application, the date, time and the history of your use of our services.
COFFEE BREAK undertakes to:
• Collect, process or store your personal data for the sole purpose of achieving specific, legitimate and relevant purposes for which you have given us your consent,
• Keep your personal data for a period of time that is strictly in line with the purpose and the nature of our processing,
• Ensure the confidentiality of your data by allowing its disclosure only to the recipients designated for its processing or, to the extent permitted or required by law, to comply with a legal, regulatory or judicial obligation or any other demand of a State authority, to detect, prevent or deal with fraudulent activities, security breaches or any technical problem, or to protect against imminent harm to the rights, property or security of COFFEE BREAK, its users or the public,
• Ensure your right to obtain information by responding to your questions about the processing of your data and by respecting your rights of access, correction, deletion or objection,
• Keep you informed about technical measures taken to secure your personal data.
Article 3 - IP ADDRESSES AND COOKIES
The COFFEE BREAK Web server automatically collects IP addresses and information relating to the use of this Website (as well as certain other information such as the type of browser used and operating system) from its users. COFFEE BREAK can also monitor the user's use in order to measure the Website's general activity, to analyze and make improvements to it and to disclose cumulative statistics on the number of users.
COFFEE BREAK may use cookies to record Website activity in order to manage it more effectively and to improve it for your use. Cookies are small text files sent and stored in your computer that allow Web servers to recognize users' habits, facilitate their access to Websites, and allow Websites to compile aggregate data that will improve the Website and its content. Cookies do not damage computers or files.
Cookies by themselves cannot be used to discover the user's identity. If you do not want COFFEE BREAK to have access to the cookies, in accordance with French Law 78-17 of January 6, 1978 relative to information technology and freedoms, and particular to Article 32, your web browser allows you to deny or disable the use of cookies by setting your browser accordingly:
• For Mozilla Firefox:
o Choose on the "Tools" menu then "Options"
o Click on the "Privacy" icon
o Locate the "Cookie" menu and select the options that suit you.
• For Microsoft Internet Explorer:
o Choose the "Tools" menu, then "Internet Options"
o Click on the "Confidentiality" tab
o Select the desired level using the cursor.
• For Google Chrome:
o Click on the "Wrench" icon in the browser's toolbar
o Choose the "Options" menu and then click on "Advanced Options"
o Click on "Content Settings" in the "Privacy" section
o Click on the "Cookies" tab and select the options that suit you
• For Opera 6.0 and beyond:
o choose the "File" menu > "Preferences"
o Privacy
As every browser has different capabilities, please refer to the "Help" section in your browser for more information on how to deny or disable the use of cookies.
However, please note that cookies may be necessary to allow COFFEE BREAK to function properly. In case of the Participant's refusal of these cookies, COFFEE BREAK will not be able to guarantee the proper functioning of all of its Service's features.
Article 4 - STORAGE AND PROCESSING OF DATA
Your data is processed in confidential ways and is not communicated to any third party without your consent. It is particularly possible that we may be required by law, in specific cases, to disclose your data to the authorities responsible for investigations. The transfer and disclosure of your data is carried out in accordance with the legislation in force.
Personal information collected on the Website may also be transferred to and stored in a country outside of the European Economic Area ("EEA"), for the purposes of data conservation and the operation and maintenance of the Website. These countries may not provide the same level of data protection as that conferred by the laws of your country. The transfer of data to countries not providing protection similar to that of your local law is protected by standard contractual clauses signed between COFFEE BREAK and the recipients of the data located in these countries. COFFEE BREAK will take all steps reasonably necessary to ensure that your data is processed securely and in accordance with this Personal Data Protection Charter. Unfortunately, the transmission of information via the Internet is not completely secure. Although COFFEE BREAK takes all reasonable precautions to protect your personal data, the security of data transmitted on the Website cannot be guaranteed and any transmission is at your own risk. Upon receipt of your information, COFFEE BREAK will use strict procedures and security features to try to prevent unauthorized access.
Article 5 - USE OF THE PERSONAL INFORMATION COLLECTED
The use of your data is also required for communication purposes in order to thus make a help service and support available that meets your expectations. Subject to your consent, we use your data to keep you regularly informed, by email only, about our news, events and special activities. In any case, COFFEE BREAK uses the personal identification information provided by you for the purposes for which you have provided it. COFFEE BREAK collects data when you open an COFFEE BREAK account, and when you use certain products and services. COFFEE BREAK may also receive personal information about you from its business partners, who must ensure that they are authorized to send it.
COFFEE BREAK may propose to its Participants or visitors to the Website their participation in loyalty programs, marketing or other activities taking place on a Website or a third party program. In this case, COFFEE BREAK is not responsible for the actions or activities of such third parties and encourages its visitors to carefully consult the terms and conditions proposed by such third parties. COFFEE BREAK may also use personal identification information to transmit to third parties (such as marketing service suppliers) the metadata such as the user database and the usage patterns. Nevertheless, COFFEE BREAK will not sell or disclose the personal identification information provided by you to any third party outside of its related and partner companies, or its respective agents or consultants, who act in the name of or on behalf of COFFEE BREAK and are subject to confidentiality obligations.
In addition, COFFEE BREAK may share or transfer personal data in order to comply with laws or legal obligations, to establish or exercise rights recognized by law, or property rights, or to defend itself against legal redress, or in the case of a merger, acquisition, reorganization or a similar fact.
Article 6 – YOUR RIGHTS TO ACCESS AND CORRECT YOUR DATA
You have the right to exercise your right to object to COFFEE BREAK's use of your personal data for commercial purposes. You can exercise your right in order to prevent this processing by checking certain boxes on the forms we use to collect your data. You can also exercise your right to object at any time by contacting COFFEE BREAK (see our contact details below).
COFFEE BREAK may at any time display links to or from the websites of our partners, advertisers and affiliated networks. If you follow a link to one of these websites, please note that these websites have their own Personal Data Protection Charters, and we disclaim any responsibility related thereto. Please consult these Personal Data Protection Charters before transmitting any personal data to these websites.
In accordance with French Law No. 78-17 of January 6, 1978, relative to information technology, files and freedoms, and European Directive N° 95/46 of October 24, 1995 on the protection of individuals with regard to the processing of personal data and the free movement of such data, Participants registered on the Website have a right of objection, access and correction of such data (if the request for deletion of information concerns items necessary for the proper functioning of the Participant's account, the account would be deleted).
As a result, any Participant registered on COFFEE BREAK has the right to require that the information concerning him be corrected, supplemented, updated or deleted. This right may be exercised directly online on our website (contact form), or by mail via the following address:
PHMC GPE LLC – COFFEE BREAK
Marketing Department
2915 Ogletown Road
Newark DE-19713 U.S.A.
Any access request may be subject to a commission limited to the costs incurred to transmit to you the details of the information we hold concerning you.
Article 7 - PROTECTION OF CHILDREN
COFFEE BREAK users under the age of eighteen (18) are not allowed to disclose personal information or to use the public discussion areas without the consent of their parents or guardians.
If your children disclose personal data on COFFEE BREAK or on the public discussion areas, they may potentially receive unsolicited messages from third parties. Accordingly, you are responsible for making sure that they comply with the applicable Terms and Conditions of Use, warning them about sharing personal data and controlling their use of the Website. If you are worried about your children's activities or respect for their confidentiality on our Websites, we encourage you to send us an email.
Article 8 - AMENDMENT TO THIS CHARTER
COFFEE BREAK may update this Personal Data Protection Charter at any time. COFFEE BREAK will notify you of significant changes regarding the processing of personal identification information by posting a notice on COFFEE BREAK. COFFEE BREAK encourages you to regularly consult this Personal Data Protection Charter.
Any amendments to this Charter will take effect immediately upon notification by any means, such as a message put online on the Website homepage, an email, or a postal letter. However, changes to the purposes for the collection, use and disclosure of your personal data may be implemented only with your express permission, or only to the extent authorized or prescribed by law.
Any use of COFFEE BREAK subsequent to these amendments will be considered acceptance of these amendments, with the exception of a change to the intended purposes for the collection, use or disclosure of your personal data. If you no longer wish to be bound by the terms of the amended Charter, you must immediately stop using the Website.
Rev 2.00 May 25th, 2018
Rev 2.00 May 25th, 2018