Privacy policy

Last updated on 18/11/2024.

PREAMBLE

This privacy policy informs you about how Convergence uses and protects the information that you provide to us, where applicable, when you use this website accessible at the following URL: www.agence-convergence.com  (hereinafter the “Site”).
Please note that this privacy policy may be amended or supplemented at any time by Convergence, in particular in order to comply with any legal or technological developments. In such a case, the date of its update will be clearly indicated at the top of this policy. These amendments are binding on the User as soon as they are published online. The User should therefore consult this privacy policy regularly in order to take note of any amendments.

ARTICLE 1.    PARTIES

This privacy policy applies between the publisher of the Site, namely Convergence, hereinafter “Convergence”, and any person connecting to the Site, hereinafter the “User”.

ARTICLE 2.    DEFINITIONS

  • “Site Content”: elements of any kind published on the Site, whether or not protected by an intellectual property right, such as texts, images, designs, presentations, videos, diagrams, structures, databases or software.
  • “User”: any person connecting to the Site.
  • “Site”: the website accessible at the URL https://www.agence-convergence.com/ as well as the related sub-sites, mirror sites, portals and URL variations.

ARTICLE 3.    SCOPE OF APPLICATION

This privacy policy applies to every User. Simply browsing the Site constitutes your full and unreserved acceptance of this policy.
The User acknowledges the evidential value of Convergence's automatic recording systems and, unless the User provides evidence to the contrary, waives the right to challenge them in the event of a dispute.
Acceptance of this privacy policy presupposes that Users have the legal capacity required to do so or that they are at least 16 years of age, or failing that, that they have the authorisation of a guardian or curator if they lack legal capacity, of their legal representative if they are under 16 years of age, or that they hold a mandate if they are acting on behalf of a legal entity.

ARTICLE 4.    PERSONAL DATA

In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on 14 April 2016, and with the applicable national legislation, Convergence provides you with the following information:

4.1    Identity of the data controller

The party responsible for the collection and the data processed is 
Convergence, SARL (limited liability company), 
SIREN: 344 600 598,  
registered office: 135 Boulevard du Maréchal Leclerc, 33000 Bordeaux, France, 
Telephone +33 0 57 87 02 05
Email: contact@agence-convergence.com

4.2    Identity of the Data Protection Officer

The Data Protection Officer is 
Deshoulières Avocats Associés, 
121 boulevard de Sébastopol 75002 Paris, 
tel.: +33.1.77.62.82.03, 
rgpd@deshoulieres-avocats.com, 
www.deshoulieres-avocats.com.

4.3    Data collection by CONVERGENCE

4.3.1    Data collected 

4.3.1.1    Data collected while browsing
While browsing the Site, you consent to Convergence collecting information relating to: 
-    Your use of the Site; 
-    The content you have viewed; 
-    Your demographic data; 
-    The device you use and your software environment; 
-    Your geographical location; 
-    Your connection data (times, pages viewed, IP address, etc.);
-    Trackers, web beacons, web storage, unique advertising identifiers;
-    Web pages visited before or after using the Site.


4.3.1.2    Data collected when using the contact form
The User's use of the contact form entails the collection by Convergence of the following personal data:
-    First name;
-    Surname;  
-    Email address; 
-    Telephone number; 
-    Position held;
-    Company name.

4.3.1.3    Data collected when using the newsletter form
The User's use of the newsletter form entails the collection by Convergence of the following personal data:
-    Email address.

4.3.2    Purposes of the collection of personal data
The data collected while browsing is subject to automated processing for the purposes of:
-    Developing, operating, improving, providing and managing the Site; 
-    Contextualising and improving the User's experience. 
.
The data collected when using the contact form is subject to automated processing for the purposes of:
-    Verifying the User's identity;
-    Providing the User with a detailed response;
-    Sending information to and contacting Users, including by email, telephone and push notification.

The data collected when using the newsletter form is subject to automated processing for the purposes of: 
-    Sending a newsletter; 
-     Sharing content from the site and/or the application with other people or making it known to such others. 

4.3.3    Legal bases for processing
The legal basis for the data collected while browsing is Convergence's legitimate interest, namely analysing behaviour on the Site and achieving improved security and operation of the Site. With regard to data resulting from the placement of certain cookies, the User is invited to refer to the Convergence cookies policy.
The legal basis for the data collected when using the contact form is the consent of the data subjects.
The legal basis for the data collected when using the newsletter form is the consent of the data subjects.

4.3.4    Internal recipients of the data
The data collected may be viewed only by the members of Convergence's management and by the staff responsible for managing the website and the relationship with Users, and is never made freely viewable by any third-party natural person.

4.3.5    Retention period for personal data
Personal data collected while browsing is retained for a reasonable period necessary for the proper administration of the Site and for a maximum of 12 months, or until the data subjects withdraw their consent. 
Personal data collected when using the contact form is retained for a reasonable period necessary for the proper handling of the User's request, and for a maximum of 12 months.
Personal data collected when using the newsletter form is retained until the User unsubscribes from that newsletter. 
At the end of each of these periods, Convergence will archive this data and retain it for the period during which its liability may be incurred. 
Once this retention period has expired, Convergence undertakes to permanently delete the data of the data subjects.

4.3.6    Security and confidentiality of personal data
Personal data is stored under secure conditions, using current technical means, in compliance with the provisions of the General Data Protection Regulation and the applicable national legislation.

4.3.7    Minimisation of personal data
Convergence may also collect and process any data provided voluntarily by a User, in particular when sending an email to the contact address. 
Convergence guides Users as far as possible when they provide unnecessary or superfluous personal data.
Convergence undertakes to retain and process only the data strictly necessary for its activities, and will delete any unnecessary data received as soon as possible.

4.4    Respect for your rights

You have the following rights concerning your personal data, which you may exercise by writing to us at our postal address or by sending an email to the following address: privacy@agence-convergence.com.

4.4.1    Right to information, access and communication of data
You have the possibility of accessing the personal data concerning you.
Owing to the obligation of security and confidentiality in the processing of personal data incumbent upon Convergence, your request will only be processed if you provide proof of your identity, in particular by producing a scan of your valid identity document (in the case of a request by email) or a signed photocopy of your valid identity document (in the case of a request made in writing), both accompanied by the statement “I hereby certify on my honour that the copy of this identity document is a true copy of the original. Done at … on …”, followed by your signature.
To assist you with your request, you will find here a template letter drawn up by the French Data Protection Authority (CNIL).

4.4.2    Right to rectification, deletion and the right to be forgotten
You have the possibility of requesting the rectification, updating, blocking or erasure of your personal data which may prove to be inaccurate, erroneous, incomplete or out of date.
You may also set general and specific directives concerning the fate of your personal data after your death. Where applicable, the heirs of a deceased person may require that the death of their relative be taken into account and/or that the necessary updates be made.
To assist you with your request, you will find here a template letter drawn up by the CNIL.

4.4.3    Right to object to data processing
You have the possibility of objecting to the processing of your personal data. 
To do so, you should send an email to the following address: privacy@agence-convergence.com. In this email, you must specify the data you wish to have deleted as well as the reasons justifying this request, except in the case of commercial prospecting.

4.4.4    Right to data portability
You have the right to receive the personal data you have provided to us in a transferable, open and machine-readable format.

4.4.5    Right to restriction of processing
You have the right to request that the processing of your personal data by Convergence be restricted. Your data may then only be stored and no longer used by Convergence.

4.4.6    Withdrawal of consent
Your consent is essential to the processing of your data by Convergence. However, you may withdraw it at any time. Such withdrawal will result in the deletion of the personal data concerning you. 
However, the services requiring the processing of your data by Convergence will no longer be accessible.

4.4.7    Response times 
Convergence undertakes to respond to your request for access, rectification or objection, or any other additional request for information, within a reasonable period which shall not exceed 1 month from receipt of your request.

4.4.8    Complaint to the competent authority
If you consider that Convergence is not complying with its obligations with regard to your personal information, you may lodge a complaint or a request with the competent authority. In France, the competent authority is the French Data Protection Authority (CNIL), to which you may submit a request here.

4.5    Transfer of collected data 

4.5.1    Transfer to partners 
Convergence informs you that we use authorised service providers to facilitate the collection and processing of the data you have provided to us. These service providers may be located outside the European Union and receive the data collected on the Site.
Convergence has previously ensured that its service providers implement adequate safeguards and comply with strict conditions regarding confidentiality, use and protection of data.
The User consents to the collected data being transmitted by Convergence to its partners and being processed by these partners in connection with third-party services, namely:

Register of processors

Partner

Recipient country

Processing carried out

Safeguards

AWS

 United States and EU

Website hosting 

https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice_2024-07-01_FR-FR.pdf

Microsoft 

United States 

Email service, data hosting 

https://privacy.microsoft.com/fr-fr/privacystatement#mainwherewestoreandprocessdatamodule

Google Analytics 

United States 

Production of commercial statistics in order to generate reports on Users' interactions

https://policies.google.com/privacy/frameworks

Linkedin 

United States 

Online professional social network

www.linkedin.com/legal/privacy-policy

Matomo 

EU

Web statistics measurement tool

https://fr.matomo.org/gdpr-analytics/

Hotjar  

EU 

Website experience analytics tool for behavioural analysis

https://www.hotjar.com/legal/policies/privacy/

Galilée

France  

IT expert 

See contractual clause 

4.5.2    Transfer upon official requisition or court order
The User also consents to Convergence disclosing the collected data to any person, upon the requisition of a state authority or pursuant to a court order.

4.5.3    Transfer in the context of a merger or acquisition
If Convergence is involved in a merger, a sale of assets, a financing transaction, a liquidation or bankruptcy, or in an acquisition of all or part of its business by another company, the User consents to the collected data being transmitted by Convergence to that company and to that company carrying out the processing of personal data referred to in this privacy policy in place of Convergence.

ARTICLE 5.    INTELLECTUAL PROPERTY

5.1    Legal protection of the Site Content

The Site Content may be protected by copyright and database law. Any representation, reproduction, translation, adaptation or transformation, in whole or in part, carried out unlawfully and without the consent of Convergence or its successors or assigns constitutes a breach of Books I and III of the French Intellectual Property Code and may give rise to legal proceedings for infringement.

5.2    Contractual protection of the Site Content

The User contractually undertakes towards Convergence not to use, reproduce or represent, in any manner whatsoever, the Site Content, whether or not protected by an intellectual property right, for any purpose other than that of its reading by a robot or a browser. This prohibition does not apply to indexing robots whose sole purpose is to scan the content of the Site for indexing purposes.

ARTICLE 6.    FINAL PROVISIONS

6.1 Amendments 

This Privacy Policy may be amended at any time by Convergence.  The terms applicable to the User are those in force at the time of their connection to the Site, and any new connection to the Site entails acceptance, where applicable, of the new terms.

6.2    Entire agreement

The invalidity of any one of the clauses of this agreement shall not entail the invalidity of the other clauses of the agreement or of the agreement as a whole, which shall retain their full force and scope. In such a case, the parties shall, as far as possible, replace the invalidated provision with a valid provision corresponding to the spirit and purpose of these terms.

6.3    No waiver

The failure by Convergence to exercise the rights granted to it hereunder shall in no circumstances be interpreted as a waiver of the right to assert said rights.

6.4    Languages

These terms are offered in French.

6.5    Unfair terms

The provisions of these terms apply subject to compliance with the mandatory provisions of the French Consumer Code concerning unfair terms in contracts concluded between a professional and a consumer.

ARTICLE 7.    DISPUTES

7.1    Applicable law

This Privacy Policy is governed by French law and by European regulations, in particular the European General Data Protection Regulation.

7.2    Disputes

Pursuant to French Ordinance No. 2015-1033 of 20 August 2015, any disputes that may arise in connection with the performance of these general terms and for which no amicable solution has first been found between the parties must be submitted to an accredited mediator.

7.3    Arbitration

Any dispute relating to or in connection with this agreement shall be settled by arbitration in accordance with the FastArbitre rules of the Institut digital d'arbitrage et de médiation (French Digital Institute of Arbitration and Mediation).
 

 

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