Privacy policy
Article 1 – Data controller and scope of application
Data controller: Mouratoglou Academy, a société par actions simplifiée (simplified joint stock company) with a single shareholder governed by French law, registered in the Paris Trade and Companies Register under number 410 939 136 RCS, with its registered office at 37, rue la Pérouse 75016 Paris, France (hereinafter referred to as “MA” or “we”).
MA, via its website 🔍 http://www.mouratoglou.com (hereinafter the “Site”) and the video-surveillance/videoprotection system installed to ensure the safety of persons and property, located at the Académie Mouratoglou at 3550 route des Dolines, 06410 Biot (hereinafter the ” Premises “), collects and processes certain personal data relating to its users (“you” or the “User(s)”).
Personal data is any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to that person, such as their physical, economic, cultural or social identity (the ” Personal Data “).
In accordance with the General Regulation of the European Parliament and of the Council on Data Protection No. 2016/679 of 27 April 2016 (the ” GDPR “) and Law No. 78-17 of 6 January 1978 known as the “Data Protection Act” in its current version (the ” Applicable Regulations “), this privacy policy & cookies policy (the ” Policy “) is intended to inform you as fully as possible about the data that we collect about you, the processing that we carry out and its purpose, the retention periods, the recipients and the rights that you have when using the Site.
Modification of the Policy: The Policy may be modified at any time. The current version is the one available on the Site. If there is a material change to the Policy, we will notify you within a reasonable time (by email or by banner on the Site).
MA may ask you at any time and by any means that can be recorded to confirm that you have read and understood the Policy.
Article 3 – Data collected by MA
3.1. Data provided to MA by Users
MA processes the data that the User communicates to it via the Site and/or via the contact form, in particular during the following operations:
data relating to the device used to access and use the Site: technical information concerning the characteristics and operating data of the User’s device, the operator, the operating system, the IP address ;
any other information directly and voluntarily provided by the User, and in particular the content of e-mails or messages sent.
In accordance with the amended French Data Protection Act of 6 January 1978 and European Regulation No. 2016/679 of 27 April 2016, MA, in its capacity as Data Controller, collects the above information in order to manage your account, provide you with the services requested, apply our general terms and conditions of sale, manage your requests, carry out analyses and statistics and comply with our legal obligations and as part of our legitimate interests. If you consent and depending on your activity on the site, we will send you commercial communications (offers and new products, information on products likely to interest you, etc.).
The data collected will be communicated only to the following recipients: the data department, the marketing department and the sales department.
The data is kept for three (3) months.
Data is not transferred outside the European Union.
You may access your personal data, rectify it, request its deletion or exercise your right to limit the processing of your data. You may withdraw your consent to the processing of your data at any time; you may also object to the processing of your data; you may also exercise your right to the portability of your data. Finally, you can decide what happens to your data after your death.
To exercise these rights or if you have any questions about the processing of your data under this scheme, you can contact our DPO by e-mail at rgpd@mouratoglou.com, or by post at the head office address].
Proof of identity may be requested if there are reasonable doubts about your identity.
If, after contacting us, you feel that your “Data Protection” rights have not been respected, you may submit a complaint to the CNIL.
The e-mail address that the User must provide to subscribe to the newsletter or contact MA’s customer service is compulsory as it is impossible for MA to process the request without this information.
MA to process the request without this information.
3.2. Data collected by means of cookies
3.2.1. What are cookies?
The Site is likely to use cookies depending on the preferences you have expressed when connecting to the Site for the first time or at any time thereafter.
- Cookies are small files that are stored on the User’s computer or on any communications device used by the User (telephone, tablet) when browsing the Site. These files enable status information to be exchanged between the Site and the User’s browser. This data may reveal the type of browser used, the date and time of the visit, the IP address and the activities carried out on the Site. This data enables MA to remember the User when he/she uses the Site and to record his/her browsing habits:
to improve security and navigation on the Site ;
for audience measurement, analysis and statistical purposes;
to send and display targeted advertising.
- Who can place cookies on my terminal?
– MA
– MA’s partners: such as its affiliates, i.e. any company that controls it, that it controls or that is placed under common control with it, “control” being understood within the meaning of article L.233-3 of the French Commercial Code.
- Cookies may be deposited when you browse our Site or when you click on our advertising spaces from our Site or partner sites.
3.2.2. What types of cookies are used on the Site?
MA uses the following categories of cookies on its Site:
Strictly necessary cookies:
These cookies are essential to enable you to browse the Site and use its features. Without these cookies, the services you have requested, such as storing your connection data, cannot be provided. These cookies also store the choices you make. They can therefore be used to offer you an experience that is better adapted to your choices and to make your visits more pleasant and more personalised.
Your consent is not required for this type of cookie.
How long they are kept: they are generally kept for the duration of the session and for a maximum of several months.
Consequences in the event of blocking: you may no longer be able to access the Site.
Detailed purposes:
– to retain your choice regarding the deposit of cookies ;
– to personalise the user interface (for example, for the choice of language or the presentation of the Site); to record the format and dimensions of your screen and your windows in order to display our Site correctly;
– combat spam and phishing attempts, by enabling us to identify computers used to create a large number of fake accounts;
– detect computers infected by malicious software and prevent them from causing damage;
– detect navigation problems and consequently improve the ergonomics of our Site;
– route traffic between servers and understand how fast our pages load;
– facilitate communication via the Site;
– to measure the audience, the number of visitors and to produce statistics on our Site, in particular to improve the functionality of the Site.
Audience measurement cookies (subject to your prior consent)
Google Analytics :
The Site also uses Google Analytics to track the performance of the Site and enable MA to optimise your online experience. These cookies collect information about how Users use the Site in order to gather information such as how often Users visit the Site, what pages they view and what other sites they visited before coming to the Site. The information we obtain through Google Analytics is used for the sole purpose of improving the Site.
Retention period: The lifetime of these cookies does not exceed 13 months.
Consequences of blocking: No consequences for the User, but by accepting them you are helping to improve our Site.
To block this cookie directly via Google, please visit the following site: 🔍 Google Analytics opt-out browser add-on – Analytics Help
Detailed purposes :
– to measure the audience, traffic and performance of our Site to improve the functionality of the Site;
– to analyse traffic in greater detail.
Content personalisation cookies (subject to your prior consent):
These cookies do not directly store personal data, but are based on the unique identification of your browser and terminal. These cookies enable us to deduce your user profile and recommend content that best suits your preferences.
How long they are kept: They are kept for a very short time, generally for the duration of the session, a few hours and a maximum of 13 months.
Consequences in the event of blocking: No consequences for use of the Site. However, deleting them will result in content being displayed that does not take your centres of interest into account. By accepting these cookies, you benefit from an enriched and personalised experience.
Detailed purposes:
– to offer you personalised content based on your preferences, interests and your browsing and use of the Site;
– identify your visit to our Site, track the pages you visit and the links you click; understand your user profile to better tailor our Site and the advertising displayed on it to your interests. If you have given us permission to send you advertising e-mails (in particular newsletter subscriptions), we will also use this information to personalise them (targeting or advertising cookies).
Personalised advertising cookies (subject to your prior consent):
These cookies may be set within our Site by our advertising partners. They may be used by these companies to establish a profile of your interests and to offer you relevant and personalised advertising on other websites. These cookies make it possible to display advertising that best matches your preferences. Your profile is also enhanced with information from your interactions with our partners or with other publishers who are customers of these partners.
Retention period: They are kept for a very short period, generally the duration of the session, a few hours and a maximum of 13 months.
Consequences in the event of blocking: No consequences for use of the Site. On the other hand, deleting them will not stop advertising on the Internet. The only effect will be to display advertising that does not take your centres of interest into account. By accepting these cookies, you benefit from an enriched and personalised experience.
Detailed purpose:
– to offer you personalised content based on your preferences, centres of interest and your browsing and use of the Site;
– to count the total number of advertisements displayed by us on our advertising spaces, to identify these advertisements, their respective number of displays, the number of users who clicked on each advertisement and, where applicable, the subsequent actions taken by these users on the pages to which these advertisements lead;
– to adapt the advertising content of our Site through our advertising spaces as well as our offers, according to navigation on our Site, or third party sites, purchases that you may make and/or according to location data (longitude and latitude) transmitted by your terminal (with your prior consent);
– to associate this data with browsing information in order to send you, for example, electronic advertising or to display on your terminal, within advertising spaces that we issue, personalised advertising specifically intended for you and likely to be of personal interest to you.
3.2.3. How do I configure the placement of cookies?
The User’s prior consent is required before reading or depositing cookies that are not strictly necessary for the operation of the Site, i.e. on this Site, cookies for audience measurement, content personalisation and personalised advertising.
In accordance with the CNIL’s recommendation on the subject, MA obtains the User’s consent by means of the following tools:
1. a banner:
When you first connect to the Site, a banner is displayed to inform you about the categories of cookies that are used and to give you the opportunity to accept or refuse cookies related to (i) audience measurement, (ii) content personalisation, (iii) personalised advertising.
Once you have made your choices, a cookie is placed on your terminal to store them for 6 months. This prevents us from asking you to configure your cookies each time you visit our Site.
This banner allows the User :
– directly accept the deposit of all types of cookies; or
– directly refuse the deposit of all types of cookies for which consent is mandatory; or
– to choose, on a granular basis, the purposes of cookies for which the User wishes to give or refuse consent; and/or
– to choose precisely each of MA’s partners who may use cookies and the purposes for which they wish to use them.
If you wish to change these settings at a later date, you must access the cookie management platform.
2 Setting your browser or terminal parameters
You can also configure your browser or terminal to manage cookies in general, regardless of the website or application concerned. The configuration of each browser is different. It is described in your browser’s help menu, which will tell you how to modify your cookie preferences. Rejecting or deleting cookies may prevent the site in question from functioning properly.
The CNIL informs you here: 🔍 les-conseils-de-la-cnil-pour-maitriser-votre-navigateur (in French only)
3 Youronlinechoices.com (for advertising cookies)
Finally, you can log on to the Youronlinechoices site, which is run by digital advertising professionals belonging to the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France (IAB). You can find out which companies have signed up to this platform and offer the option of deactivating interest-based advertising by using 🔍 the tool provided on this site. This does not mean that you will no longer receive advertising when you browse the Internet, but that what you see displayed on the websites visited will no longer be particularly tailored to you and your interests, and may therefore be less relevant.
Article 4 – Use of User data
As the data controller, MA collects Users’ personal data lawfully and fairly and respects their rights.
The information collected by MA, including personal data, is used for the following purposes:
– To manage the User’s subscription to MA’s newsletters and commercial prospecting messages;
– To manage the video surveillance system of the Premises in order to ensure the safety of persons and property, the images recorded in this system not being used for the purposes of staff surveillance or time and attendance control;
– Manage the Site and its operational functions (including logistics), resolve any technical problems, improve and develop new functionalities based on use and/or feedback and requests from Users;
– To carry out statistical analyses;
– Respond to Users’ requests and communicate with them; ;
– Apply current legislation and regulations;
Finally, Users have the option of having their telephone details entered on the Bloctel opposition list managed by Opposetel. Bloctel is the telephone canvassing opposition list on which any consumer can register free of charge in order to no longer be canvassed by telephone by a professional with whom they have no current contractual relationship.
You can find all the information on how to register on this list at the following link: https://conso.bloctel.fr/
Article 5 – Legal basis for processing
The processing carried out by MA is based on :
– MA’s legitimate interests (and in particular its economic interests): in particular, processing for the purpose of managing the Site and its operational functions (including logistics), resolving any technical problems, improving and developing new functions based on use and/or feedback and requests from Users, compiling statistics, sending commercial canvassing, and ensuring the safety of persons and property through the video surveillance/video protection system installed on the Premises.
This processing contributes to the improvement of the Site and thus benefits both the User and MA without infringing the fundamental interests, rights and freedoms of Users;
– consent for the management of cookies
– consent for the registration form.
Article 6 – Users’ rights regarding their personal data
In accordance with the Applicable Regulations, as a “User” you have the following rights with regard to your personal data, which may be exercised by contacting MA, whose contact details are given in article 14 below:
– right to information: you have the right to obtain clear, transparent, comprehensible and easily accessible information on how we use your personal data and on your rights. This is why we provide you with the information in this Policy.
– right of access: you have the right to access the personal data we hold about you and to obtain a copy of it (provided that the request is not manifestly unfounded or excessive, in particular because of its repetitive nature).
– right of rectification: you have the right to demand that your personal data be rectified if it is inaccurate or out of date and/or that it be completed if it is incomplete.
– right to erasure: in certain cases, you have the right to obtain the erasure or deletion of your personal data. This is not an absolute right, as we may be obliged to retain your personal data for legal or legitimate reasons.
– Right to restriction of processing: This right means that our processing of your data is restricted, so that we may retain the data but may not use or process it. This right applies in specific circumstances, namely:
In cases where the accuracy of the personal data is disputed by the data subject (i.e. you): Processing is then restricted for a period to allow MA to verify the accuracy of the personal data;
If the processing is unlawful and the data subject (i.e. you) objects to the erasure of the personal data and requests instead that its use be restricted;
In cases where MA no longer needs the personal data for the purposes of processing, but the data is still necessary for the data subject to establish, exercise or defend legal claims;
– to find out whether or not the legitimate reasons pursued by MA prevail over those of the data subject.
– the right to object to the processing of your personal data where the processing is based on MA’s legitimate interests (to determine what processing is involved, please refer to Article 5 of this Privacy Policy): you may at any time object to the processing of your personal data on grounds relating to your particular situation, unless MA can show compelling legitimate grounds for processing such data which override your interests, rights and freedoms, or where such data is necessary for the establishment, exercise or defence of legal claims. If you wish to exercise your right to object or obtain more information on how to exercise this right, please contact us using the details below.
– Right to data portability: you have the right to receive the personal data that you have provided to us and that we hold about you, in a structured, commonly used and machine-readable format. This applies only to data that you have provided directly or indirectly and only where processing is based on your consent or the performance of a contract and is carried out by automated means. We invite you to consult the list of legal bases for our processing of personal data (see article 5 of this Privacy Policy) to find out whether our processing is based on a contract or on consent. To exercise your right to data portability or obtain further information, please contact us using the details below.
– For Users residing in France, the right to send us specific instructions concerning the fate of your personal data after your death.
– right to lodge a complaint with a supervisory authority: you have the right to lodge a complaint with the data protection authority in your country (in France the Commission Nationale de l’Information et des Libertés and in other European countries the authorities listed here) to challenge MA’s personal data protection and privacy practices.
Article 7 – Communication of Users’ personal data
MA undertakes to retain all personal data collected and to share such data only in certain circumstances and in accordance with Applicable Regulations.
– Disclosure of Users’ Personal Data to MA Employees:
Some of the Users’ personal data is accessible to MA’s employees if these persons need to have access to it in order to carry out the aforementioned purposes. The internal departments of MA that may have access to Users’ personal data are the IT department, the technical support department, the marketing/sales department, the coaches, the legal department and the human resources department.
– In the event of an incident, the images recorded by the video surveillance and/or protection system may be viewed by authorised personnel (e.g. security or human resources staff).Communication of Users’ personal data to third-party service providers:
The User’s personal data may be shared with third parties for the following reasons:
– as part of a merger, acquisition or sale of all or part of the company’s assets, of which the User acknowledges having been informed;
– in response to legal or administrative proceedings of any kind or to law enforcement measures requested by the competent authorities;
– to comply with legal obligations, to protect the rights and/or safety of an individual, to protect the rights and property of MA, including the need to ensure compliance with this Policy, and to prevent fraud, security or technical problems. In the event of an incident, the images recorded by the video surveillance and/or protection system may be viewed by the forces of law and order. The staff of the companies responsible for maintaining the video surveillance equipment and security guards may also access the images for this purpose only.
Article 8 – Retention of Users’ personal data
The personal data collected by MA is stored on the servers of a service provider located in the European Economic Area.
MA requires this service provider to take, in accordance with Applicable Regulations, all organisational and technical measures to ensure an adequate level of protection for Users’ personal data.
MA retains personal data for 3 years from the date of your last contact with MA.
Article 9 – Transfers of personal data outside the European Union
Prior to any transfer outside the EU, MA has ensured that:
(i) the countries of destination provide an adequate level of protection for personal data recognised by the European Commission; or
(ii) appropriate safeguards have been adopted (for example, by signing with the recipient the standard contractual clauses adopted by the European Commission or authorised by a supervisory authority).
At the date the Policy was updated, the countries outside the EU concerned were : Australia, China, Dubai, Malaysia, United States of America.
Article 10 – Security and protection of Users’ personal data
The security of personal data is one of MA’s priorities. MA undertakes to take all reasonable organisational and technical measures to prevent any disclosure, use, alteration, accidental loss or destruction of a User’s personal data.
Article 11 – Changes to the Policy
MA may update this Policy at any time to adapt it to any new practices. In this case, the date of the Policy update will be updated to indicate the day on which the changes were made. Users are responsible for checking any updates to this Policy posted on the Site. If MA makes significant changes, Users will be notified by e-mail.
Article 12 – Links to third-party websites
While browsing the Site, the User may see content containing links to third-party mobile applications and/or websites. MA cannot access or control cookies or other functions used by third-party mobile applications and/or websites, and the procedures of these external mobile applications are not governed by this Policy. Consequently, it is up to the User to contact and/or consult directly the general terms of use and privacy policy of these third party mobile applications and/or websites to obtain additional information regarding their personal data protection procedures.
Article 13 – Contacting MA
Insofar as data protection is an important issue today, MA has chosen to voluntarily appoint a Data Protection Officer. This is the service provider The Neoshields (DPMS group).
If the User has any questions or comments about this Policy, or about MA’s use of his/her data, he/she may contact the Data Protection Officer at the following address: rgpd@mouratoglou.com
Proof of identity may be requested if there are reasonable doubts about your identity.
If, after contacting us, you feel that your “Data Protection” rights have not been respected, you may submit a complaint to the CNIL.