The Policy may be subject to change. SPRING LEGAL will post any changes to this Policy on this page. Although SPRING LEGAL will notify Visitor(s) of any material changes to this Policy, SPRING LEGAL encourages Visitor(s) to review this Policy periodically.
If the Visitor(s) have any questions about this Policy or the processing of their collected data, they should contact SPRING LEGAL at the following email address: firstname.lastname@example.org
For the purposes of this Policy, the following definitions apply:
- “I&L Regulations”, all laws and regulations in force or to come in France regarding the protection of personal data, and in particular the law n°78-17 of January 6, 1978 known as “Informatique et Libertés” in its version in force at the date of acceptance of the T&Cs and/or subsequently revised as well as the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (RGPD) ;
- “Collected Data”, any personal data(s) (hereinafter “PAD”) presenting information relating to an identified or identifiable person in a direct or indirect manner ;
- “Processing” means any operation(s) or set of operations that has (have) an impact or is (are) likely to have an impact on PAD, regardless of the process used, and in particular the collection, recording, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, reconciliation, as well as blocking, erasure or destruction as defined by the I&L Regulation.
The Policy describes the commitments undertaken by SPRING LEGAL to protect DCP collected and processed in the context of the use of its Site and its functionalities.
1. CATEGORIES OF PROCESSED DATA
SPRING LEGAL only collects DCP that is relevant and necessary for the proper use of the Site and the features that SPRING LEGAL offers to Visitors. SPRING LEGAL undertakes to specify which DCPs are necessary and/or optional for the proper functioning of the functionalities of its Site, each time the DCPs of Visitors are collected. This is information that the Visitor(s) communicates directly or indirectly to SPRING LEGAL, in particular when the Visitor(s) : SPRING LEGAL only collects DCP that is relevant and necessary for the proper use of the Site and the features that SPRING LEGAL offers to Visitors. SPRING LEGAL undertakes to specify which DCPs are necessary and/or optional for the proper functioning of the functionalities of its Site, each time the DCPs of Visitors are collected. This is information that the Visitor(s) communicates directly or indirectly to SPRING LEGAL, in particular when the Visitor(s) : This is information that the Visitor(s) communicates directly or indirectly to SPRING LEGAL, in particular when the Visitor(s) :
- Contact SPRING LEGAL on the Site via the “Contact” tab;
- Accept the use of non-necessary cookies for the proper functioning of the Site;
– In this context, the FCDs that SPRING LEGAL processes are :
- Via the use of the “Contact” tab:
- Visitor’s first and last name;
- The Visitor’s personal or business telephone number;
- The Visitor’s personal or professional email address;
- Any personal data that may be contained in the message indicated by the Visitor;
- The time stamp of the Visitor’s request.
– Through the use of the cookie system :
- Data relating to the Visitor’s linguistic preferences;
- Data relating to the Visitor’s functional preferences;
- Data relating to the Visitor’s presentation preferences.
2. PURPOSES OF THE PROCESSING AND LEGAL BASES
The PADs collected by SPRING LEGAL are processed for the following purposes and on the following legal grounds:
- The management of requests relating to personal data on the legal basis of the fulfilment of the legal obligations of SPRING LEGAL ;
- The adaptation of the website according to the preferences of the Visitor on the legal basis of his free specific and informed consent.
- DCP collected by SPRING LEGAL will never be used for any other, unanticipated purpose, unless the individual has given their written consent.
DCP collected by SPRING LEGAL will never be used for any other, unanticipated purpose, unless the individual has given their written consent. No personal information other than that indicated in this Policy is collected without the knowledge of the individuals concerned through the use of the Site.
3. RECIPIENTS OF THE DCP
The DCP collected on the Site is intended for use by authorized SPRING LEGAL personnel in the performance of their duties. They are for internal use only and are not communicated, transferred or disclosed to third parties, except with the consent of the Visitor or in compliance with a legal obligation by SPRING LEGAL.
Subject to having obtained the Visitor’s prior express consent for this specific purpose, SPRING LEGAL may transmit information concerning them to its partners, within the framework of marketing and commercial and promotional operations, whether joint or not.
SPRING LEGAL may transfer Visitors’ DCPs to :
- Technical providers of IT services, such as hosting services, technical support for SPRING LEGAL’s software and applications that may contain DCP about Visitors;
- Administrative, judicial and guardianship authorities, when such communication is required by law.
- Law firms or legal companies likely to be of interest to the Visitor with regard to his original request.
Where SPRING LEGAL has called upon a subcontractor or partner to process the Visitor’s DCPs, SPRING LEGAL ensures that the said subcontractor/partner presents sufficient guarantees as to the implementation of appropriate technical and organizational security measures so that the processing carried out complies with the requirements of the I&L Regulation and guarantees the protection of the rights of the Data Subject.
Moreover, the DCPs collected on the Site are not transferred outside the European Union.
If Visitors are affected by a merger, reorganization, dissolution or other fundamental change of SPRING LEGAL, or if SPRING LEGAL sells the Site or a business unit that includes the DCP of certain Visitors, or if all or a portion of SPRING LEGAL’s business, assets or inventory is acquired by a third party, SPRING LEGAL agrees that it may share DCP with that third party for the purposes of such transaction, subject to receipt of the prior favorable consent of the affected person. In accordance with the I&L Regulation and more generally with the applicable laws, SPRING LEGAL will inform the Visitors concerned of any transfer of DCPs to a third party.
Finally, SPRING LEGAL may share anonymized Visitor data with SPRING LEGAL’s service providers in order to assist SPRING LEGAL in its analysis and improvement of services related to its business and/or the Site.
4. RETENTION PERIODS OF THE DCP
SPRING LEGAL has determined precise rules concerning the length of time it keeps the Visitor’s personal data collected on the Site. This duration varies according to the different purposes of treatment specified in this Policy and must take into account the possible legal obligations to keep some of the DCPs. Thus the data is kept until the purposes for which they were collected are achieved.
Concerning the DCP collected via the form of the tab “CONTACT” they are kept for the time of the management of the requests relating to the Visitor’s message.
After these time limits, SPRING LEGAL will delete or anonymize the information or, if this is not possible, SPRING LEGAL will securely archive the DCPs and isolate them from further use until deletion is possible.
5. SECURITY OF COLLECTED DCP
SPRING LEGAL promises to keep the processed personal data secure and only for as long as is necessary to achieve the purpose of the processing.
To this end, SPRING LEGAL takes the appropriate physical, technical and organizational measures to prevent, as far as possible, any alteration, loss or unauthorized access to the Visitor’s DCPs.
If SPRING LEGAL becomes aware that a third party to whom it has disclosed DCP for the purposes set forth above is using or disclosing DCP in a manner inconsistent with this Policy or in violation of applicable law, SPRING LEGAL will take steps to immediately terminate such use.
6. THE VISITOR’S RIGHTS
In accordance with the I&L Regulation, the Visitor has the following rights on their DCP:
- Right of access, which authorizes the obtaining of information concerning the Visitor’s DCPs and a copy of them;
- Right of rectification, which authorizes, when the Visitor’s DCPs are inaccurate, to demand that they be modified accordingly;
- Right to erasure (right to be forgotten), which allows the deletion or removal of the Visitor’s DCPs;
- Right of opposition, which authorizes the Visitor to oppose any use by SPRING LEGAL of his DCP for reasons related to his particular situation;
- Right to the limitation of Processing, which authorizes the Visitor to request the limitation of the Processing that SPRING LEGAL carries out on the DCP concerning him;
- Right to portability (ability to retrieve data upon request), which allows the Visitor to obtain an electronic copy or transfer of his CPDs from the SPRING LEGAL database to another;
- The Visitor may also define directives relating to the conservation, deletion and communication of his DCPs after his death.
To exercise his rights, the Visitor must send his request by e-mail to this address : email@example.com or send a registered letter with acknowledgement of receipt, enclosing a copy of your identity card, to :
42, Rue Vignon
SPRING LEGAL undertakes to respond to the data subject’s request within a maximum of one month after receiving it. If the said right invoked by the Visitor cannot be exercised, SPRING LEGAL will inform the Visitor of the reasons within a maximum of one month.
Subject to a breach of the above provisions, the Visitor has the right to lodge a complaint with the Commission Nationale Informatique et Libertés (CNIL), the French supervisory authority in matters of DCP.
The Site’s Web server deposits cookies on the Visitor’s hard drive, subject to consent. The cookies necessary for the proper functioning of the Site are not subject to the Visitor’s consent.
The purpose of the cookies deposited is to technically recover information relating to the types and habits of navigation of the Visitor in order to directly propose to him a presentation and a more adapted parameter setting of the Site.
SPRING LEGAL uses preferential cookies and statistical cookies for the Site.
Preferential cookies allow the Site to remember information that changes the way the Site behaves or displays, such as the Visitor’s preferred language or region. The preferential cookies used are: “wpglobus-language” and “wpglobus-language-old”. They expire after one year. They expire after one year.
Statistical cookies help SPRING LEGAL, through the collection and communication of anonymous information, to understand how Visitors interact with the Site in order to improve its performance. The statistical cookies are: “_ga” and “_ ga_#”. They expire after two years. They expire after two years.
The Visitor’s choices can be modified at any time.
When the Visitor accepts or refuses the deposit of cookies via the Site, a cookie is installed on his browser to store his choice and thus not to solicit him again during a later use of the Site. This absence of solicitation is not perpetual.
Each browser has a different configuration for managing cookies and its choices. It is described in the help menu of the browser used, which will allow you to know how to modify the settings regarding cookies.
For Internet Explorer™ https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
For Safari™ : https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=fr_FR
For Chrome™ : https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en
For Firefox™ : https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences