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Privacy Policy

Effective date: April 8, 2020. Updated on April 24, 2023

SAMA P-A ("we", "us", "our") operates the website https://sama-pa.org (hereinafter referred to as the "Service").

This page explains our policies regarding the collection, use and disclosure of personal information when you use our Service and the choices you have regarding that information.

We use your information to provide and improve the Service. By using the Service, you consent to the collection and use of information in accordance with this policy.

Definitions

  • Service By Service we mean the website https://sama-pa.org operated by M.LOIZE Kévin
  • Personal data Personal Data means data about a living individual who can be identified from that data (or from that data and other information in our possession or likely to come into our possession).
  • Usage Data Usage Data: Usage Data is collected automatically and is generated either by the use of the Service or by the infrastructure of the Service itself (e.g., page view time).
  • Cookies Cookies are small files stored on your device (computer or mobile device).
  • Person in charge of the treatment Data Controller means the natural or legal person (alone, or jointly or in common with others) who determines the purposes and manner in which all personal data is or is to be processed. For the purposes of this Privacy Policy, we are a Data Controller of your personal data.
  • Subcontractors (or Service Providers) Subcontractor: The term Subcontractor (or Service Provider) refers to any natural or legal person who processes data on behalf of the Data Controller. We may use the services of more than one Service Provider in order to process your data more efficiently.
  • Person Concerned (or User) Data Subject: A Data Subject is any living person who uses our Service and is the subject of Personal Data.

Data collection and use

We collect several types of data for different purposes in order to provide and improve our Service to you.

Types of data collected

Personal Data

When you use our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you ("Personal Information"). Personally Identifiable Information may include, but is not limited to

  • E-mail address
  • First and last name
  • Cookies and Usage Data

We may use your Personal Information to send you newsletters, marketing communications or promotions and other information that may be of interest to you.

You can choose not to receive any communications from us or to receive only certain communications by clicking on the unsubscribe link or by following the instructions in each email we send.

Usage Data

We may also collect information about how you access and use the Service ("Usage Data"). This Usage Data may include information such as the Internet Protocol address (i.e., IP address) of your computer, browser type, browser version, the pages of our Service you visit, the date and time of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

Tracking and cookie data

We use cookies and other similar tracking technologies to track activities on our Service, and we retain certain information.

Cookies are small data files that may contain an anonymous unique identifier. Cookies are sent to your browser from a website and are stored on your device. Other tracking technologies such as pixels, tags and scripts are also used to collect and track information and to improve and analyze our Service.

You can set your browser to refuse all cookies or to alert you when a cookie is being sent. However, if you do not accept cookies, you may not be able to use certain features of our Service.

Examples of cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and settings.
  • Security Cookies. We use security cookies for security purposes.

Cookie settings / disable option :

Cookie settings

Use of the data

SAMA P-A uses the collected data for various purposes:

  • To provide and maintain our Service
  • To let you know about changes to our service
  • To allow you to use the interactive features of our Service when you want
  • To provide assistance
  • To collect valuable data or analysis that will allow us to improve our Service
  • To monitor the use of our Service
  • To detect, prevent and solve technical problems
  • To provide you with news, special offers and general information about other goods, services and events we offer that are similar to those you have already purchased or inquired about, unless you have previously indicated that you do not wish to receive such information.

Legal basis for processing personal data under the General Data Protection Regulation (GDPR).

If you reside in the European Economic Area (EEA), SAMA P-A's legal basis for collecting and using the personal data described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

SAMA P-A may process your Personal Data:

  • Because we need to fulfill a contract with you
  • Because you allowed us to do so
  • Because we have a legitimate interest in carrying out this processing and
    your rights do not override this legitimate interest
  • For payment processing purposes
  • To comply with the law

Data retention

SAMA P-A will retain your Personal Information only as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary for us to fulfill our legal obligations (e.g., to comply with applicable law), resolve disputes and enforce our agreements and policies.

SAMA P-A will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except where such data is used to enhance security or improve the functionality of our Service, or where we are legally required to retain such data for a longer period.

Data transfer

Information about you, including your Personal Information, may be transferred from your region, province, country, or other territorial division to, and stored on, computers located in a place where data protection laws differ from those of the territory in which you reside.

If you reside outside of France and choose to provide us with information, please be aware that we transfer data, including Personal Information, to France and London and process it there.

By agreeing to this Privacy Policy and then submitting this information, you consent to this transfer.

SAMA P-A will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and your Personal Data will not be transferred to any organization or country unless adequate controls are in place, including with respect to the security of your data and other personal data.

Data communication

Reporting of data to law enforcement

In certain circumstances, SAMA P-A may be required to disclose your Personal Data if required by law or in response to valid requests from public authorities (e.g., a court or government agency).

Legal requirements

SAMA P-A may disclose your Personal Data if it has a good faith belief that it is necessary to:

  • Fulfilling a legal obligation
  • Protect and defend the rights or property of SAMA P-A
  • Prevent or investigate potential wrongdoing in the Service
  • Ensure the personal safety of the users of the Service or the public
  • Protecting yourself against liability

Data security

The security of your data is important to us. However, please keep in mind that no method of transmitting data over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable methods to protect your Personal Information, we cannot guarantee its absolute security.

Data protection rights granted to you by the General Data Protection Regulation (GDPR)

If you reside in the European Economic Area (EEA), you have certain data protection rights. SAMA P-A intends to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you would like to know what Personal Information we hold about you and would like it deleted from our systems, please contact us.

Under certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we hold about you. Where this option is available, you may view or update your Personal Information or request its deletion in the settings section of your account. If you are unable to perform these actions yourself, please contact us for assistance.
  • Right of rectification. You have the right to have your data corrected if they are inaccurate or incomplete.
  • Right to object. You have the right to object to our processing of your Personal Data.
  • Right of limitation You have the right to ask us to limit the processing of your personal data.
  • The right to data portability. You have the right to receive a copy of the information we hold about you in a commonly used, structured, machine-readable format.
  • Right to withdraw consent. You also have the right to withdraw your consent at any time if SAMA P-A has relied on your consent to process your personal data.

Please note that we may ask you to prove your identity before responding to requests of this nature.

You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact the data protection authority closest to you in the European Economic Area (EEA).

Service providers

We may use third-party companies and individuals to facilitate the provision of our Service ("Service Providers"), perform the Service on our behalf, provide services related to the Service, or help us analyze how our Service is used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are prohibited from disclosing or using it for any other purpose.

Analysis

We may use third party Service Providers to monitor
and analyze the use of our Service.

Fathom : We use Fathom (https://usefathom.com/), which is the only analytics solution that does not require cookies or collect personal data for segmentation purposes. Fathom traffic passes only through European servers, operated by European companies and therefore where privacy protection standards are the highest in the world. For more information on Fathom's privacy practices, please consult Fathom's Privacy Policy and Conditions web page.

Using Google Analytics Google Analytics: In order to constantly improve and optimize our website, we use Google Analytics, a web analysis service provided by Google LLC (hereinafter "Google"). Google Analytics uses "cookies" to help the website analyze how users use the site. The information generated by these cookies about your use of our website is generally transmitted to and stored by Google on servers in the United States.

We have activated IP anonymization on our website, which means that your IP address will be truncated by Google in the member states of the European Union or in other states party to the Agreement on the European Economic Area before being transferred to the United States. The full IP address will only be transmitted to Google's servers in the United States and shortened there in exceptional cases.

Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The IP address transmitted by your browser within the framework of Google Analytics will not be associated with other data held by Google.

You can refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do so, you may not be able to use all the features of our site. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the site (including your IP address) and from processing this data by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout.

For more information on how Google treats your personal data, please consult Google's privacy policy, accessible here : https://policies.google.com/privacy. "

Akismet Akismet: Akismet is a plugin for blogging and commenting platforms that helps detect and block unwanted comments, such as spam and malicious comments. It collects information about comments, such as author, IP address, referrers and comment content, to use for spam detection. It also uses a database of comments that are considered spam to identify new comments that match these patterns. For more information on Akismet's privacy practices, please visit Akismet's Privacy Policy and Terms and Conditions web page.

Use of online platforms to offer and sell services

We offer our services on online platforms managed by other providers. In this context, the data protection policies of these platforms are in addition to our own privacy policies. This applies in particular to the processing of payment transactions, as well as to the methods used on the platforms to measure reach and implement interest-based marketing.

Processed data Identification data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contractual data (e.g. purpose of contract, duration, customer category); usage data (e.g. websites visited, interest in content, access time); metadata/communication data (e.g. device information, IP addresses).

Persons concerned Customers.

Treatment goals Contractual services and customer support.

Legal basis : performance of the contract and pre-contractual steps (art. 6, paragraph 1, point b, of the RGPD); legitimate interests (art. 6, paragraph 1, point f, of the RGPD).

Additional information on treatment processes, procedures and services :

Steady Media UG (limited liability) We use the services of Steady Media UG (limited liability), located at Schönhauser Allee 36, 10435 Berlin. Steady offers and invoices subscriptions to our publication, and provides associated services, such as setting up a paywall on our site. To this end, Steady collects and stores, among other things, potential identification data (including IP address, date, time and other technical data concerning the Internet browser used and the operating system) and checks whether a user is a member. Steady uses cookies on our website for this purpose. Steady also collects additional data from subscribers, such as e-mail address, name and subscription data. Steady's full privacy policy is available here : Website : https://steadyhq.com/fr ; Privacy policy : https://steadyhq.com/fr/privacy.

Using platforms to send newsletters

We only send newsletters, e-mails or other electronic notifications (hereinafter referred to as "newsletters") with the consent of the recipient or with legal authorization. If the content of the newsletter is specifically described at the time of registration, this is decisive for the user's consent. Our newsletters also contain information about our services and about us.

To subscribe to our newsletters, the user must generally enter his/her e-mail address. However, we may also ask for the user's name in order to address them personally in the newsletter, or for other information required for the newsletter.

Double opt-in procedure Registration for our newsletter is subject to a double opt-in procedure. This means that after registration, the user receives an e-mail in which he/she must confirm his/her registration. This confirmation is necessary to prevent anyone registering with a third party's e-mail address. Newsletter registrations are recorded in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Changes to data stored by the shipping service provider are also logged.

Deletion and limitation of processing We may retain unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests, before deleting them in order to prove prior consent. The processing of such data is limited to the purpose of any defence against claims. An individual request for deletion is possible at any time, provided that the prior existence of consent is confirmed at the same time. In the event of a permanent obligation to observe contradictions, we reserve the right to store the e-mail address in a blocking list (so-called "block list") solely for this purpose.

Registration process recording The registration process is recorded on the basis of our legitimate interests in order to prove that it has been carried out correctly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Notes on the legal basis The sending of newsletters is carried out on the basis of the recipient's consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, for example in the case of advertising for existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.

Contents Our newsletters contain information about our services, promotions and offers.

Types of data processed The data processed includes inventory data (such as names and addresses), contact data (such as e-mail and telephone numbers), metadata and communication data (such as device information and IP addresses), as well as usage data (such as websites visited, interest in content and access time).

Persons concerned Communication partners are the people involved.

Purposes of processing Processing is carried out for direct marketing purposes (e.g. by e-mail or post).

Legal basis : Processing is carried out on the basis of consent (Article 6(1)(a) of the GDPR) or on the basis of our legitimate interests (Article 6(1)(f) of the GDPR).

Opt-out option The user may cancel receipt of our newsletter at any time by revoking consent or objecting to further receipt. The link to cancel the newsletter can be found at the end of each newsletter, or the user can use one of the contact options indicated above, preferably by e-mail.

Additional information on treatment processes, procedures and services :

Measuring open and click-through rates Web beacon: Newsletters contain a "web beacon", i.e. a single-pixel file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from its server. During this retrieval, technical information such as browser information, the user's system, IP address and the time of retrieval are initially collected. This information is used to technically improve our newsletter on the basis of technical data or target groups and their reading behavior according to their retrieval location (which can be determined using the IP address) or access times. This analysis also makes it possible to determine whether newsletters are opened, when they are opened and which links are clicked. This information is allocated to individual newsletter recipients and stored in their profiles until deleted.

These evaluations help us to recognize the reading habits of our users and to adapt our content accordingly, or to send different content according to the interests of our users. The measurement of opening rates and click-through rates as well as the storage of measurement results in user profiles and their further processing are based on the user's consent. Unfortunately, separate revocation of performance measurement is not possible. In this case, the entire newsletter subscription must be cancelled or contested. In this case, the stored profile information will be deleted.

We use Amazon SES to send newsletters to our users. Amazon SES is an e-mail service that enables us to send large-scale e-mails reliably and cost-effectively.

The complete Amazon SES privacy policy is available here : Website : https://aws.amazon.com/ ; Privacy policy : https://aws.amazon.com/privacy/.

Using Cloudflare on our website

We use Cloudflare, a third-party content caching and delivery service, to improve the performance of our website and ensure the security of our users. Cloudflare uses cookies and other technologies to collect information about the use of our website, including visitors' IP addresses, browsing data, pages visited and response times.

Data collected by Cloudflare is used to improve the performance of our website, to detect and prevent DDoS attacks and other malicious activity, and to personalize content according to users' interests, including geolocation.

Cloudflare has its own privacy policy. You can read their privacy policy to learn more about how they collect, use and protect data. Here's the link to their privacy policy:

Behavioral Remarketing (not functional at the moment)

SAMA-PA uses remarketing services to show you ads on third-party sites after you have visited our Service. We and our third party vendors use cookies to shape, optimize and serve ads based on your previous use of our Service.

Payments

We may offer fee-based products and/or services as part of the Service. In such cases, we will use third party payment processing services (i.e., payment processors).

We will not collect or store your payment card information. This data is provided directly to third-party payment processors, who use your personal data in accordance with their privacy policies. These payment processors adhere to the PCI-DSS standard managed by the PCI Security Standards Council, which is a collaborative effort between brands such as Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure secure processing of payment information. The payment processing companies we work with are:

Links to other sites

Our Service may contain links to other sites that we do not operate. If you click on a third party link, you will be redirected to that third party's site. We strongly recommend that you review the privacy policy of each site you visit.

We have no control over, and are not responsible for, the content, privacy policies or practices of any third party sites or services.

Children's privacy

Our Service is not intended for persons under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you know that your Child has provided us with Personal Information, please contact us. If we learn that we have collected Personal Information from children without verifying parental consent, we will take steps to delete that information from our servers.

Changes to this Privacy Policy

We reserve the right to update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

Before the change takes effect, we will notify you by e-mail and/or by placing a prominent notice on our Service and we will update the "Effective Date" at the top of this Privacy Policy.

We recommend that you review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when posted on this page.

Contact us

If you have any questions about this Privacy Policy, please contact us:

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