This privacy policy applies to the website: https://smartprospective.com.
The purpose of this privacy policy is to inform users of the :
This privacy policy complements the legal notice, and the General Conditions of Use which users can consult at the following address :
https://smartprospective.com/terms-of-useIn accordance with the provisions of Article 5 of the European Regulation 2016/679, the collection and processing of data of the users of the site respect the following principles :
To be lawful, and in accordance with the requirements of Article 6 of the European Regulation 2016/679, the collection and processing of personal data may only take place if they comply with at least one of the following conditions :
The personal data collected on the Smart Prospective site are the following :
This data is collected when the user performs one of the following operations on the site :
The data controller will keep in its computer systems of the website and in reasonable conditions of security all the data collected insofar as this is necessary for the purpose of the processing carried out, considering the need to answer questions or resolve difficulties, to improve or offer new services and to comply with its legal obligations in this respect (for example, accounting and legal retention periods).
This means that SMART PROSPECTIVE is required to keep your personal data for a reasonable period after the end of the processing, in accordance with the legal and regulatory obligations that apply to SMART PROSPECTIVE (for example, accounting and legal retention periods) and sufficient for the settlement of disputes, the exercise or defence of SMART PROSPECTIVE’s rights in the countries where it is established.
The personal data collected by the site are not transmitted to any third party and are only processed by the site editor.
The Smart Prospective website is hosted by :
OVH, whose headquarters are located at the following address :
2, rue Kellermann BP 80157 59053 ROUBAIX Cedex 1
The host can be contacted on the following telephone number : +33 (0)8 203 203 63
The data collected and processed by the site are exclusively hosted and processed in France.
The person responsible for processing personal data is Damien DELBOS. He can be contacted in the following way :
dpo@smartprospective.com
The data controller is responsible for determining the purposes and means of processing personal data.
The data controller undertakes to protect the personal data collected, not to pass them on to third parties without the user's knowledge and to respect the purposes for which the data was collected.
The site has an SSL certificate to ensure that information and data transfer through the site is secure.
An SSL certificate ("Secure Socket Layer" Certificate) is intended to secure the data exchanged between the user and the site.
In addition, the data controller undertakes to notify the user of any rectification or deletion of the data, unless this would involve disproportionate formalities, costs, and steps for the user.
If the integrity, confidentiality, or security of the user's personal data is compromised, the controller undertakes to inform the user by any means.
In accordance with the regulations concerning the processing of personal data, the user has the following rights.
For the data controller to comply with the request, the user is required to provide the following information: first and last name, e-mail address and, if relevant, account number or personal space or subscriber number.
The data controller is obliged to respond to the user within a maximum of fifteen (15) days.
a. Right of access, rectification, and erasure
The user may view, update, modify or request the deletion of data concerning him/her, in accordance with the procedure set out below :
The user must send an e-mail to the person responsible for processing personal data at dpo@smartprospective.com specifying the subject of the request.
If he/she has one, the user has the right to request the deletion of his/her personal space by following the procedure below :
The user must send an e-mail to dpo@smartprospective.com requesting the deletion of his personal space. The request will be processed within thirty (30) days.
b. Right to restrict and object to data processing
The user has the right to request the limitation of or to oppose the processing of his/her data by the site, without the site being able to refuse, unless it can be shown that there are legitimate and compelling reasons, which can prevail over the interests and rights and freedoms of the user.
To request the limitation of the processing of his/her data or to formulate an objection to the processing of his/her data, the user must follow the following procedure :
The user should send an e-mail to dpo@smartprospective.com requesting that the processing of his/her data be restricted or that he/she objects to the processing of his/her data.
c. Right not to be subject to a decision based exclusively on an automated process
In accordance with the provisions of Regulation 2016/679, the user has the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning him or her, or significantly affects him or her in a similar way.
d. Right to determine the fate of data after death
The user is reminded that he/she can organise what should happen to his/her collected and processed data if he/she dies, in accordance with law n°2016-1321 of 7 October 2016.
e. Right to refer to the competent supervisory authority
If the data controller decides not to respond to the user's request, and the user wishes to contest this decision, or if he/she believes that one of the rights listed above has been infringed, he/she is entitled to refer the matter to the CNIL (Commission Nationale de l'Informatique et des Libertés, https://www.cnil.fr) or to any competent judge.
In accordance with the provisions of Article 8 of the European Regulation 2016/679 and the French Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data.
If the user is a minor under the age of 15, the consent of a legal representative will be required for personal data to be collected and processed.
The site editor reserves the right to verify by any means that the user is over 15 years of age, or that he has obtained the agreement of a legal representative before browsing the site.
The site may use "cookie" techniques.
A "cookie" is a small file (less than 4 kb), stored by the site on the user's hard drive, containing information about the user's browsing habits.
These files enable it to process statistics and information on traffic, to facilitate navigation and to improve the service for the user's comfort.
For the use of "cookie" files involving the storage and analysis of personal data, the user's consent is necessarily requested.
This consent of the user is considered valid for a period of 6 (six) months maximum. At the end of this period, the site will again request the user's permission to save "cookies" files on his or her hard disk.
a. Opposition of the user to the use of "cookies" by the site
Cookies that are not essential to the operation of the website are only placed on the user's terminal after obtaining the user's consent. The user can refuse his or her consent on the declaration relating to cookies on our website or by withdrawing it later on the dedicated page.
More generally, the user is informed that he/she may oppose the recording of these "cookies" by configuring his/her browser.
For information, the user can find at the following addresses the steps to follow to configure his browser software to oppose the recording of "cookies" files :
If the user decides to deactivate the "cookies" files, he/she will be able to continue browsing the site. However, any malfunctioning of the site caused by this manipulation cannot be the fault of the site editor.
b. Description of the "cookies" files used by the site
The site editor draws the user's attention to the fact that different types of cookies are used during navigation. Some cookies are placed by third party services that appear on our pages.
The user's attention is drawn to the fact that these sites have their own privacy policies and general conditions of use that may differ from the site. The site editor invites users to consult the privacy policies and general conditions of use of these sites.
This privacy policy can be consulted at any time at the following address :
https://smartprospective.com/security
The site editor reserves the right to modify it to ensure its conformity with the law in force.
Therefore, the user is invited to consult this privacy policy regularly to be informed of the latest changes.
The user is informed that this privacy policy was last updated on : 04/08/2022.
By browsing the site, the user certifies that he/she has read and understood this privacy policy and accepts its conditions, particularly regarding the collection and processing of his/her personal data, as well as the use of "cookies" files.
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