This privacy policy is a translation of the French language version of the Closd privacy policy. In case of any discrepancies between the French language version and this version, the French language version shall prevail.

This privacy policy details how Closd uses and collects the personal data of the visitors (the “Personal Data”) of the website (the “Website”) and informs them of the measures taken to ensure their protection during the visit of the Website in accordance with the provisions of law n° 78-17 dated 6 January 1978 in relation to computer processing, data and freedom (the “Informatique et Liberté law”) and regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”).

By visiting the Website, the visitors expressly agree to the collection and to the usage rules of the Personal Data as described hereafter.

The visitors may exercise their rights towards Closd at the following e-mail address:

1. Processing agent

The Personal Data transmitted upon browsing the Website is collected by Closd.

2 Collected Personal data

The Personal Data that may be collected by Closd during the consultation of the website is the following:

  • Mame, e-mail address, company name and phone number of the visitors wishing to ask a question or contact Closd via the online form or the dedicated contact page;
  • IP address, connection and browsing data of the visitors.
3. Purposes

Closd processes the Personal Data for the following purposes:

  • Treatment of your questions and requests to be called-back;
  • Website traffic analysis.
4. Recipients of the collected Personal Data

The collected Personal Data is exclusively processed by Closd.

Closd does not transmit the collected Personal Data to any third party, for any reason whatsoever.

Closd may nevertheless be compelled to transmit Personal Data in order to comply with applicable legislation and comply with requests issued by public or governmental authorities. In such case, a prior notice will be transmitted to the relevant visitor unless Closd is prohibited to do so by virtue of applicable legislative or regulatory provisions.

5. Retention period of Personal Data

Closd does not retain Personal Data beyond the period necessary to the achievement of the relevant data processing.

6. Visitors’ rights

Visitors, according and within the limitations of articles 5, 16, 17, 18 and 20 of the GDPR, benefit from a right of consultation, rectification, and deletion of their Personal Data and limitation of processing of their Personal Data, as well as a portability right with regard to the Personal Data transmitted to Closd.

The visitors may also send specific instructions with regard the post-mortem utilisation of their Personal Data.

The visitors may exercise their rights towards Closd at the following e-mail address:

The visitors are also informed that they may, in accordance with article 77 of the GDPR, raise a reclamation with the Commission Nationale de l’Infomatique et des Libertés (CNIL) if they consider that the processing of their Personal Data by Closd constitutes a breach of the GDPR

7. Utilisation of cookies

A cookie is a small text file that contains information about your activity on the Website. It allows for instance to remember some of your preferences without having to ask you again on every visit.

Closd exclusively uses technical cookies that have no impact on the Personal Data of the visitors.

8. Closd commitments

Closd commits to respect its applicable obligations in relation with any personal data protection regulation, notably the French Informatique et Liberté law and the GDPR.

In particular, Closd guarantees that it will:

  • cooperate with the relevant data protection authority, notably in case of request of information or control;
  • collaborate and assist the visitors by setting up, if possible, appropriate technical and organisational measures in order to answer the requests of the visitors wishing to exercise their rights under applicable legal provisions;
  • set up every necessary measure in order to provide for:
    • security of the Personal Data against any wilful or unwilful breaches, notably in relation to the requirements provided under articles 32 to 34 of the GDPR;
    • confidentiality of the Personal Data, notably ensuring that authorised data processing personnel commits to respect the confidentiality of the data in order to maintain an appropriate level of security in relation to the risk;
  • inform the visitors of any security breach, as soon as possible after being aware of such breach, and take any appropriate measure in order to correct it;
  • o depending on the choice of the visitor, delete the Personal Data or send it back to the visitor on agreed an medium and destroy the existing copies, unless applicable legal or regulatory provisions require the conservation of the Persona Data.
9. Modification of the privacy policy

Closd reserves the right to modify this privacy policy, notably to make it compliant with applicable legal or regulatory provisions.

In case of modification, the updated privacy policy will be uploaded on the Website with the indication of the latest modification date.

Last update : 25 may 2018


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