Introduction
The privacy of visitors to our website is very important to us, and we are committed to protecting it. This policy explains what we do with your personal information.
Information gathering
The following types of personal information may be collected, stored and used:
- Information about your computer, including your IP address, your geographical location, your browser type and version, and your operating system;
- Information about your visits to and use of this website, including the referring source, videos and pages viewed, the duration of your visit to each page, and your navigation paths on the website (information used, in particular, to update the visitor counter);
- Information such as your email address, which you provide when you register for our training courses;
- Information you enter when you create a profile on our platform, such as your name, profile picture and address;
- Information such as your name and email address, which you enter to subscribe to our emails and/or newsletters;
- Information you enter when using our platform’s services;
- Information generated whilst using our platform, including when and how often you use it;
- Information relating to the services you use or transactions carried out on our platform, which includes your name, address, telephone number, email address and bank details;
- Information you post on our platform with the intention of publishing it on the internet, including your username, profile photos and the content of your posts;
- Information contained in all communications you send to us by email or via our platform, including their content and metadata;
- Any other personal information you provide to us.
- Before disclosing personal information about another person to us, you must obtain that person’s consent to the disclosure and processing of that personal information in accordance with the terms of this policy.
Use of personal information
Personal information provided to us via our platform will be used for the purposes set out in this policy or on the relevant pages of the website. We may use your personal information to:
- To manage our platform and website;
- To personalise our platform to improve the service we offer and meet your support needs;
- To enable you to use the services offered on the platform;
- To contact you by email and/or telephone;
- To provide you with a high-quality service and a better user experience;
- To send you statements, invoices and payment reminders, and to collect your payments;
- To send you non-marketing-related commercial communications;
- To send you email notifications that you have specifically requested;
- To send you our newsletter by email, if you have requested it (you may inform us at any time if you no longer wish to receive our newsletter);
- To send you marketing communications relating to our company or to carefully selected third-party companies which we believe may be of interest to you, via email or similar technology, if you have expressly given your consent (you may inform us at any time that you no longer wish to receive marketing communications);
- To provide statistical information about our users to third parties (without these third parties being able to identify individual users from this information);
- To process enquiries and complaints relating to our platform (enquiries made by you or concerning you);
- To maintain the security of our platform and prevent fraud;
- To verify compliance with the terms and conditions governing the use of our platform (including monitoring private messages sent via the messaging service);
- Other uses.
- If you submit personal information on our website for the purpose of publication, we will publish it and may use this information in accordance with the permissions you grant us.
- Without your explicit consent, we will not provide your personal information to third parties for their direct marketing purposes, nor for those of other third parties.
Online Privacy
We are the sole owners of the information collected on this website. Your personal information will not be sold, exchanged, transferred or disclosed to any other company for any reason without your consent, except where necessary to fulfil a request and/or a transaction.
Disclosure to third parties
We do not sell, exchange or transfer your personally identifiable information to third parties. However, we may disclose your personal information to any of our employees, directors, insurers, professional advisers, agents, suppliers or subcontractors to the extent that this is reasonably necessary for the purposes set out in this policy, provided that such parties agree to keep this information confidential. We may disclose your personal information to any member of our organisation, to the extent that this is reasonably necessary for the purposes set out in this policy. We may disclose your personal information:
- In so far as we are required to do so by law;
- In connection with any current or future legal proceedings; To establish, exercise or defend our legal rights (including providing information to others for the purposes of preventing fraud and illegal activities, mitigating credit risks, addressing situations involving potential threats to the physical safety of any person, and addressing breaches of our terms of use);
- To any person whom we reasonably believe to be part of a court or other competent authority with jurisdiction over the disclosure of such personal information, if, in our opinion, such a court or authority is likely to request the disclosure of such personal information.
- Unless otherwise stated in this policy, we will not pass on your personal information to third parties. Non-personal information, however, may be provided to other parties for marketing, advertising or other purposes.
Data transfer
Your personal data is not transferred outside the European Union by either us or our service providers (hosting providers, ISPs, etc.). However, with your consent, certain data, in particular testimonials and videos of our services, may be published on our websites and platforms. Where applicable, this content may be viewed by any user of these websites and platforms from any country in the world. Finally, we also use video-conferencing and messaging applications to organise our training courses and meetings; your personal data entered via these applications may be stored outside the European Union by the owners of these applications, who remain fully responsible for ensuring the security and confidentiality of such data (To find out more about our policy on the use of applications, click on the link to the policy on the use of applications to be inserted here)
Data security.
To ensure the best possible protection of your personal data within our churches, we follow a series of security measures, the main ones of which are listed below:
- Our website, including this page, is secured using the HTTPS protocol.
- All data on our website is regularly backed up.
- We also ensure the traceability of our data processing operations, particularly those involving the most sensitive data.
- We adhere to a strong password policy and practise sound access control management.
- A log of connections to our information systems is also maintained.
- Our data, including that of our service providers, is hosted on secure servers.
- We use up-to-date antivirus software across all our information systems.
- We also have an IT policy setting out reasonable organisational measures to safeguard security and prevent the loss, misuse or alteration of your personal information, whether transmitted online or offline (management of access rights, confidentiality, precautions regarding the use of IT equipment, various security rules, etc.).
- Regular monitoring of data retention within our organisations is planned.
- We implement a range of security measures to safeguard your personal information and protect sensitive information transmitted online. We also protect your information offline.
- We will take reasonable technical and organisational precautions to safeguard your personal information and prevent its loss, misuse or alteration, whether transmitted online or offline.
- Only employees who need to carry out specific tasks (administration, billing, customer service) have access to personally identifiable information.
- The computers and servers used to store personally identifiable information are kept in a secure environment.
- You acknowledge that the transmission of information over the internet is inherently insecure, and that we cannot guarantee the security of your data sent over the internet.
- Password creation (automatic): The platform automatically generates 8-character passwords for its Users (when ordering a product or a training course). Password creation (manual). Customers and Users of the Platform must provide a password of at least 8 characters, comprising at least: – one lower-case letter; – one upper-case letter; – one number. You are responsible for keeping the password you use to access our website confidential; we will not ask you for your password.
Retention periods
We undertake to retain your Personal Data only for as long as is strictly necessary for the processing operations specified in accordance with the aforementioned purposes, and in any event within the limits imposed by law. Accordingly, depending on the type of Personal Data, the retention period may vary from a few days to several years. In any event, we undertake to delete your Personal Data from our databases at the end of these various retention periods. However, we may retain certain information for a period following the closure of your personal account in order to comply with our legal, accounting and tax obligations and, in particular, to prevent any unlawful behaviour after the deletion of your personal account (such as the reuse of your former account by a third party). In such cases, your data will be deactivated and will no longer be accessible online.
Cookies
- Cookie retention period. In accordance with the CNIL’s recommendations, the maximum retention period for cookies is 13 months from the time they are first placed on the User’s device; this also applies to the validity period of consent to the use of these cookies. The lifespan of cookies is not extended with each visit. The platform therefore ensures that the data subject’s consent is renewed at the end of this period.
- Purpose of cookies. Cookies may be used for statistical purposes, in particular to optimise the services provided to users, by processing information relating to the frequency of visits, the personalisation of pages, as well as the actions carried out and the information viewed. The platform may place cookies on your device after obtaining your express consent. The cookie records information relating to your browsing activity on the service (the pages you have viewed, the date and time of your visit, etc.), which we may access during your subsequent visits.
- Right to refuse cookies; disabling them may result in a reduced service You acknowledge that you have been informed that the platform may use cookies, and you consent to this. If you do not wish cookies to be used on your device, most browsers allow you to disable cookies via the settings. However, please be aware that some services may no longer function correctly.
- Cookies may be linked to personal data to enable the service to function. Kyria Consulting may collect browsing information through the use of cookies.
Consent
By using our website, you agree to our privacy policy.
Amendments
We may occasionally update this policy by publishing a new version on our platform. Any changes made to this policy will be communicated to you by email or via our platform’s private messaging service.
Unsubscribe
We use the email address you provide to send you information and updates about our products and services. If at any time you wish to unsubscribe and stop receiving emails, detailed instructions on how to do so are included at the bottom of every email.
Deleting an account
- Account deletion on request. End users may delete their account at any time, either by simply requesting this from Kyria Consulting or via the account deletion menu in the account settings, where available.
- Account deletion in the event of a breach of the Privacy Policy. In the event of a breach of one or more provisions of these Terms or any other document incorporated herein, Kyria Consulting reserves the right, at its sole discretion and without prior notice, to terminate or restrict your use of and access to the services, your account and the Platform.
Exercice des droits
In accordance with the GDPR and the amended CNIL Act, you have a number of rights regarding your data, as listed below, and we are committed to ensuring that you can exercise them. To exercise these rights, you may contact us by email at contact@kyriaconsulting.com or by post at 1 rue de Stockholm, 75008 Paris, France. We will reply within a maximum of one month from the date we actually receive your request.
To help us process your request quickly, please use the details (surname, first name, login details, contact details) already held by our systems and departments when contacting us.
If you write to us by post, we recommend sending your letter by registered post to ensure your request can be traced.
- Right of access: You may at any time request to view any personal data that KYRIA CONSULTING may have collected and held about you. This right also entitles you to request a copy of such data. For example, you may request a copy of your testimonials or any video recordings relating to you, subject to technical feasibility…
- Right to rectification: If you believe that your data is incorrect or out of date, you may contact us at any time to request that it be amended.
- Right to erasure: If you have a legitimate interest in exercising this right, you may request the erasure of all or part of the data we hold about you. This right may be exercised where you consider, amongst other things, that your data has been collected unlawfully; is no longer necessary for the purposes for which you provided it; is being used for purposes other than those for which we collected it; or you have withdrawn your consent… Please be aware, therefore, that the deletion of all or part of your data could result in the termination of some or all of the services we provide to you within our churches.
- Right to object: You have the right to object at any time to any processing of the data we have collected from you.
- Right to restriction: you may request that the processing of all or part of your personal data that we collect be suspended. Where applicable, we will cease all processing of such data, except to store it until your restriction is lifted. This right may be exercised, in particular, where you contest the accuracy, lawfulness or relevance of the processing of your data. Please also be aware that restricting the processing of all or part of your data may result in the interruption of all or part of the services we provide to you within our churches.
- Right to data portability: You have the right to request that the data we hold about you be transferred to other organisations. Kyria Consulting is committed to offering you the option of having all your personal data returned to you upon request. This ensures that the User has greater control over their data and retains the ability to reuse it. This data must be provided in an open and easily reusable format, directly to another data controller where this is desired and technically feasible.
- Right to information regarding automated decisions: To date, KYRIA CCONSULTING does not use any automated systems to make decisions concerning its clients.
Guidance in the event of a security breach
- KYRIA CONSULTING undertakes to implement all appropriate technical and organisational measures, using physical and logistical security measures, to ensure a level of security appropriate to the risks of accidental, unauthorised or unlawful access to, disclosure, alteration, loss or destruction of your personal data.
- In the event that KYRIA CONSULTING becomes aware of any unlawful access to your personal data stored on our servers or those of our service providers, or of any unauthorised access resulting in the materialisation of the risks identified above, we undertake to:
– Notify you of the incident as soon as possible if this is a legal requirement; – Investigate the causes of the incident;
– Take the necessary measures, within reasonable limits, to minimise the negative effects and harm that may result from the incident in question. - Limitation of liability. Under no circumstances shall the commitments set out in the point above regarding notification in the event of a security breach be construed as any admission of fault or liability in relation to the occurrence of the incident in question.
Applicable law and languages
This Privacy Policy is governed by French law. It is drafted in French. Should it be translated into one or more languages, only the French text shall be deemed authentic in the event of a dispute. The invalidity of any clause shall not render the Privacy Policy invalid as a whole. The temporary or permanent non-enforcement by KYRIA CONSULTING of one or more clauses herein shall not constitute a waiver on its part of the other clauses herein, which shall continue to have full effect.