– PERSONAL DATA AND COOKIES –

1- INTRODUCTION

As part of its commercial activity, La Barbé processes information about you. For example, by browsing our website or our mobile and digital applications, by filling in a newsletter subscription form, by clicking on an advertising link that we present to you, you transmit information to us, some of which is likely to identify you (“personal data”).

This Privacy Policy tells you how we collect and process your personal data. Please read it carefully.

Important

We only use your personal data in the cases provided for by the regulations in force:

– The performance of a contract we have entered into with you, and/or

– Compliance with a legal obligation, and/or

– Your consent to the use of your data, and/or

– The existence of a legitimate interest in using your data. A legitimate interest is a set of commercial or business reasons that justifies Barbé’s use of your data.

If you have any questions about this document, please contact Barbé’s Data Protection Officer (e-mail barbeoriginaljeep@orange.fr ).

2- WHO IS RESPONSIBLE FOR THE PROCESSING MENTIONED IN THIS DOCUMENT?

The person responsible for the processing mentioned in this document is Barbé SARL, registered in the Pau Trade and Companies Register under number RCS PAU (to come), with registered office at 6 impasse Guindalos 64110 jurançon.

Barbé’s data protection officer is M M Barbé

3- WHAT DATA DO WE COLLECT ABOUT YOU AND UNDER WHAT CIRCUMSTANCES?

3.1 Data you send us directly

During the various contacts we have with you, you may be asked to provide us with information about yourself. This information is collected in particular when you register for a newsletter, create an account on our website and application or access any other offer or service.

This includes your e-mail address and any other information you wish us to have.

3.2 Data we collect in the course of our business relationship

The data we collect in the course of our business relationship with you includes the following:

• Your participation in promotional offers, contests or events;
• Requests you have made to our community manager or incidents you have reported to us, for example concerning the performance of our services;

3.3 Data we collect automatically

Each time you visit our sites and applications, we collect information relating to your connection and navigation. Various technologies may be used to collect this data. The main one is the cookie.

• Data collected via cookies

A cookie is a text file that is stored in a specific area of your computer’s or mobile device’s hard disk when you visit a website, application or online advertisement. Cookies are managed by your Internet browser, and only the sender of a cookie can decide whether to read or modify the information contained in it.

A cookie has a limited validity period. It is deposited and stored on your terminal in compliance with applicable legislation and subject to the choices you have made, which you may modify at any time, under the conditions specified in article 9 below.

A cookie does not identify you personally. It enables its sender to recognize your terminal and to collect a certain amount of information relating to the browsing carried out from this terminal.

Cookies have several functions, such as enabling you to navigate efficiently on a site or application, remembering your choices and the goods and services you wish to purchase, and offering you relevant advertising content based on your centers of interest expressed during your browsing. For further information on cookies, please visit the following websites:

www.cnil.fr

www.allaboutcookies.org
www.aboutcookies.org
www.youronlinechoices.eu

The cookies placed by Barbé, subject to your choices, give us access to the following information in particular:

– Identifiers of the equipment you use (IP address of your computer, Android identifier, Apple identifier, etc.),

– Type of operating system used by your terminal (Microsoft Windows, Apple Os, Linux, Unix, BeOS, etc.),

– Type and version of browser software used by your terminal (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox, Google Chrome, etc.),

– Dates and times of connection to our services,

– Address of referring web page,

– Browsing data on our services, content viewed.

• Data collected by standard Internet technologies

We may also use standard Internet technologies such as scripts, pixels and redirects. Scripts (sometimes called tags), written in javascript language, are programs that run in your browser and perform various actions, such as sending information to our servers. Scripts are also capable of creating pixels. Pixels (sometimes called transparent GIFs, clear GIFs or web-bugs) are lines of code that display a graphic image (usually invisible) on a web page or in an e-mail. Redirects make a web page available under several page addresses (URLs). When a browser opens a redirect URL, a page with a different URL is opened.

The purpose of these technologies is to enhance your experience on our sites and applications, including providing you with personalized content based on your centers of interest. For example, when a user clicks on an article’s share button, a script creates a pixel that counts the shares. In this way, we are able to know the total number of shares of an article, and we can establish a ranking of the most shared articles.

These technologies give us access to the following information in particular:

– Information about your use of our sites and applications;

– Information on the presence of cookies on your terminal, on the time and date of consultation of a page, and a description of the page where the Web beacon is placed;

– Information on whether or not you read the e-mails we send you, and on the clicks you make on the links contained in these e-mails.

Our sites and applications may also include third-party scripts, pixels and redirects. These technologies enable third-party service providers to collect certain information such as your browser type, and the web page that redirected you to our websites. These third-party service providers process the information they collect for auditing and research purposes, and to report information about our sites and applications and the advertisements viewed on them. We do not share your personally identifiable information with these third parties in connection with their use of these technologies.

• Data provided by mobile devices

Some mobile devices, depending on the features you have activated (e.g. “Push” or “Geolocation”) when downloading one of our applications, send information such as your phone’s model, version of its operating system, type of connectivity, name and version of the application used.

This data, necessary for the proper functioning of the mobile applications we publish, is automatically processed by our servers and those of some of our partners (notably AT Internet, SmartAdServer) to provide you with a service and advertising tailored to the technical characteristics of your device and to measure the audience for our application.

In addition, if you have accepted this feature when downloading our applications, we are able to identify the physical location of your device (geolocation), in particular to inform you about content or offers that we think are relevant to your expectations or interests, or to improve your experience on our mobile applications. In accordance with applicable law, geolocation functions can be deactivated at any time in your device’s system settings.

3.4 The data we assume

By combining the data we have about you with general, anonymous statistical information, we may be able to make assumptions about the content and services that are likely to meet your tastes or uses.

Example: If, according to statistical data, a majority of people aged between 30 and 50, living in Pau and interested in website creation, are also passionate about social networks, and you’re a 42-year-old business owner or shopkeeper who regularly consults articles on our site related to our business, we’ll assume that you’re also interested in e-marketing, and we’ll be able to show you an advertisement for an affiliate service when you browse our site.

3.5 Data relating to minors

In principle, our products and services are intended for people of legal age who are capable of entering into contractual obligations.

Users who are minors must obtain the consent of their legal guardians prior to the communication of personal data concerning them.

For registration on our sites and for some of our online services (e.g. newsletter), the age of 16 is accepted.

Internet users under 18 years of age at the time of publication or creation of an online account have a specific right to the deletion of data concerning them. For further information, please contact the Barbé data protection officer (Clic: barbeoriginaljeep@orange.fr).

3.6 Third-party data

Before offering a service or any other product that we market to a third party, you must ensure that the person concerned agrees to their personal data, in particular their postal address, being communicated to us.

3.7 Exclusion of sensitive data

Barbé does not collect any sensitive data about you. The following are considered sensitive data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data relating to health or sexual orientation. If such information is communicated to us in any way, it will be deleted.

4- WHAT DO WE USE YOUR DATA FOR?

This article tells you the main purposes for which we use the data mentioned in article 3.

4.1 Operations required to supply products or services

• Manage subscriptions to our newsletters and/or e-mail alerts;
• Customer relations: a community manager is available by e-mail for any questions or complaints;
• Satisfaction surveys;
• Sending information about changes or developments in our services;
• Management of the exercise of your rights to your personal data, under the conditions set out in article 9;
• Verification of compliance with applicable legislation, our contracts and general conditions of use.

4.2 Marketing and sales prospecting operations relating to Barbé publications, products and services

• Update, enrich and de-duplicate your personal information in a dedicated Barbé database;
• Sending information about our company, its publications and activities;
• Sending marketing, advertising and promotional offers relating to our products and services by post, mail, e-mail, mobile notifications, on social networks or any other medium;
• Personalized sales prospecting and loyalty campaigns;
• Setting up competitions or other promotional operations;
• Customer feedback ;
• Compilation of sales statistics.

4.3 Operations linked to commercial partnerships

• Sharing, exchanging or renting files with commercial partners in compliance with current regulations and security requirements;
• Sending marketing, advertising and promotional messages relating to partners’ products and services by post, mail, e-mail, mobile notifications, on social networks or any other medium;
• Setting up competitions or other promotional operations or events with commercial partners.

4.4 Purposes associated with depositing cookies on your browser

• Operation and optimization of navigation on our sites and applications

o Adaptation of the presentation of our sites and applications to the display preferences of your terminal (language used, display resolution, operating system, etc.) during your visits, depending on the hardware and viewing or reading software that your terminal has;

o Storage of information relating to a form you have filled in on our site (registration or access to your account) or to products, services or information you have chosen on our site (service subscribed to, content consulted, purchase made, etc.);

o Automatic connection to reserved or personal areas of our site, such as your account, thanks to identifiers or data that you have previously entrusted to us;

o Provision of sharing tools on social networks;

o Management of our platforms and internal technical operations for problem-solving, data analysis, testing, research, analysis, studies and surveys;

o Implementation of safety measures ;

o Quality measures to ensure that the display of our content is adapted to your device.

• Traffic and audience measurement

o Compilation of statistics and volumes of visits to and use of the various components of our site (sections and content visited, path taken) in order to improve the interest and ergonomics of our services;

o Counting of the total number of advertisements displayed by us on our advertising spaces, classification and statistics;

o Audience analysis based on advertising campaign results;

o Determining interests and behaviors ;

o Improved customer/user knowledge for personalization purposes.

• Personalization of advertising on our sites and applications

o Adapt the advertising spaces to the display preferences of your terminal (identification of advertisements, establishment of statistics and volumes of frequentation and use of the various elements making up our site: sections and content visited, path) in order to improve the interest and ergonomics of our services;

o Adapt the advertisements displayed on your terminal when you browse our sites and applications to its technical characteristics (1), to your previous browsing choices (2), to your centers of interest and uses (3), to the data you have previously communicated to us (4) and, where applicable, to your terminal’s geographical location data (5);

o Recognize you to display personalized ads on social networks;

o Measure the effectiveness of our advertising campaigns and service proposals.

5- HOW LONG DO WE KEEP YOUR DATA?

Your personal data is kept for a period that complies with legal provisions or is proportional to the purposes for which it was recorded. Certain retention periods are in Barbé’s legitimate interest as specified in the introduction.

Retention periods vary according to whether we have an ongoing contractual relationship with you (you are an active customer), whether we have had a contractual relationship with you in the past (you are an inactive customer) or whether we have never had such a relationship with you (you are a prospect). The data relating to your browsing of our online services collected by the cookies you have authorized has a specific retention period.

The table below lists the main retention periods for your data.

In any case, we regularly review the information we hold. When its retention is no longer justified by legal or commercial requirements or in connection with the management of your customer account, or if you have exercised a right of modification or deletion, we will delete it securely.

Data categories	Goals	Shelf life
Prospect data
All data	Create and manage a prospect file	3 years from the date of collection of the data or the last contact from the prospect
Active customer data
All data	Customer account management	For the duration of the contractual relationship
Inactive customer data
Identification and contact data – Newsletter subscribers	Sending information on the evolution of our publications and offers	3 years maximum from unsubscription or last contact by the customer
Data generated by cookies
Data related to your browsing on our services online	Service operation and optimization Visitor measurements. Personalized content and advertising	13 months maximum
Assumed data
Data relating to your presumed uses and interests	Sending information and offers that are supposed to correspond to your interests and uses	Annual update

6- WHO IS LIKELY TO HAVE ACCESS TO THE DATA
THAT WE COLLECT?

6-1 Data access within Barbé

The following may have access to some of your data:

• Employees in the administrative, accounting
  and management control, IT, community management and marketing & sales departments.

Access to your data is based on individual and limited access authorizations. Personnel with access to personal data are subject to a confidentiality obligation (through a nominal and personal confidentiality undertaking).

6-2 Data transmission

The following may also have access to some of your data:

• Subcontractors

They provide services on our behalf, in particular:

• Handling telephone calls, sending postal or digital mail
• Personalizing content for websites and mobile applications
• Maintenance operations and technical developments
• Customer feedback
• Provision of analytical solutions or audience measurement statistics

Our subcontractors have access to your data on the basis of signed contracts specifying their obligations to protect data security and confidentiality.

• Social networking platforms

The use of social networks to interact with our sites and applications (in particular the “share” buttons on Facebook, Twitter and Google+) may lead to data exchanges between Barbé and these social networks. For example, if you are connected to the Facebook social network and consult a page on the Barbé site, Facebook may collect this information. Similarly, if you consult an article on the Barbé site and click on the “tweet” button, Twitter will collect this information. We therefore invite you to consult the personal data management policies of the various social networks to find out how they collect and process your data.

• Our sales partners

They promote products or services on their own behalf or on behalf of advertisers. We draw your attention to the fact that if you decide to subscribe to the products or services of our commercial partners and you allow them to access some of your information, in particular by connecting to their sites or applications, their privacy policies and their cookie deposits are enforceable against you. We have no control over the collection or processing of your data by our commercial partners on their own platforms.

• Police, judicial or administrative authorities

Where we are legally obliged to do so or in order to safeguard the rights, property and safety of Barbé

7- IS YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

We store your personal data in France. In all cases, we ensure that processing is carried out in accordance with this privacy policy and is governed by the European Commission’s standard contractual clauses, which guarantee an adequate level of protection for the privacy and fundamental rights of individuals.

8- HOW IS YOUR DATA PROTECTED?

As data controller, we implement appropriate technical and organizational measures in accordance with applicable legal provisions, to protect your personal data against alteration, accidental or unlawful loss, use, disclosure or unauthorized access, and in particular:

• Appointing a data protection officer ;
• The creation of a unit dedicated to information systems security;
• Raising awareness of confidentiality requirements among our employees who may have access to your personal data at
  ;
• Securing access to our premises and IT platforms;
• Implementation of a general corporate IT security policy;
• Securing data access, sharing and transfer;
• High standards of data protection when selecting our subcontractors and partners.

9- WHAT ARE YOUR RIGHTS?

9.1 Your rights of access to your personal data

You have the right to access your personal data and request that it be corrected, completed or updated. You may also request the deletion of your data or object to its processing, provided you can demonstrate a legitimate reason.

You can ask to exercise your right to data portability, i.e. the right to receive the personal data you have provided us with in a structured, commonly used format and the right to transmit this data to another data controller.

Finally, you can formulate directives concerning the conservation, deletion and communication of your personal data after your death.

You can exercise your rights by contacting the data protection officer at Barbé, 1074 Allée des Platanes 64160 Buros or by e-mail: barbeoriginaljeep@orange.fr

Before responding to your request, we may verify your identity and/or ask you to provide further information in order to respond to your request. We will endeavor to respond to your request within a reasonable time and, in any event, within the time limits set by law.

In the event of an unsatisfactory response, you can lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL).

9.2 Your right to object to commercial solicitations

We may use your contact details for commercial solicitations, in accordance with applicable law and the clauses of this privacy policy. You may object to these solicitations at any time, depending on the communication channel we use to send them to you.

• Electronic commercial solicitations (e-mail) :

We respect the rules of article L.34-5 of the French Post and Electronic Communications Code, which requires your prior and express consent for the sending of commercial prospecting by electronic means (e-mail, push notifications or SMS).

However, your express prior consent is not required if you are already a Le Barbé customer and the purpose of our solicitation is to offer you products or services similar to those we already provide.

In any case, you always have the option of objecting to receiving such solicitations by clicking on the unsubscribe link provided in each e-mail.

• Commercial solicitations on mobile applications

When you first open Le Barbé mobile applications on your smartphone or tablet, you can give your consent to receive mobile notifications or “push” notifications. These notifications enable us to communicate editorial content to you (news alerts, content highlighted by the editorial team), and may, from time to time, be used for commercial offers. You can deactivate these notifications at any time in your smartphone settings.

9.3 Your rights to accept and manage cookies

The registration of a cookie on your navigation terminal is subject to your will. You may at any time modify your choices regarding the acceptance or refusal of cookies placed on your terminal, either on your browser or online with various operators.

To manage cookies in the way that best suits you, we invite you to configure your browser according to the purpose of the cookies.

How do you make your choices?

1. Make your browser settings

You can set your browser either to offer you the option of accepting or rejecting cookies from time to time, before a cookie is stored, or to systematically accept or reject the storage of cookies on your terminal.

We would like to point out that any settings you make in your browser to refuse technical and functionality cookies may affect your browsing experience on our websites, and may even prevent you from using some of our services that require the use of these cookies.

Where applicable, we decline all responsibility for the consequences linked to the degraded operation of our websites and services resulting from the impossibility for us to record or consult the cookies necessary for their operation and which you would have refused or deleted.

To manage cookies and your choices, the configuration of each browser is different. This is described in your browser’s help menu, which will tell you how to modify your cookie preferences.

• Microsoft Internet Explorer
  http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
• Microsoft Edge

https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy

• Apple Safari
  http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html
• Google Chrome
  http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
• Mozilla Firefox
  http://support.mozilla.org/fr/kb/Activer%20et%20d%C3% A9sactiver%20les%20cookies
• Opera
  http://help.opera.com/Windows/10.20/fr/cookies.html

• Adobe Flash Player Flash cookies

Adobe Flash Player is a computer application that enables the rapid development of dynamic content using the Flash computer language. Flash (and similar applications) memorizes your settings, preferences and use of these contents using a technology similar to cookies. However, Adobe Flash Player manages this information and your choices via an interface different from that provided by your browser.

If your terminal is likely to view content developed using Flash, we invite you to access your Flash cookie management tools directly from the http://www.adobe.com/fr website.

• “Do not track

You can also set your browser to send a code to websites indicating that you do not wish to be tracked (“Do not track” option).

Microsoft Internet Explorer

http://windows.microsoft.com/fr-fr/internet-explorer/use-tracking-protection#ie=ie-11

Microsoft Edge

https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy

Apple Safari

http://support.apple.com/kb/PH11952

Google Chrome

https://support.google.com/chrome/answer/114836?

Mozilla Firefox

https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister

Opera

http://help.opera.com/Windows/12.10/fr/notrack.html

1. Make your choices online

For audience measurement and analytical cookies

Analytical cookies enable us to obtain anonymous statistics on visits to our site in order to optimize it and detect any malfunctions. They are placed on our sites and applications by Google Analytics and Facebook.

If you do not wish our sites and services to store cookies in your browser for audience measurement purposes, you can click on the following links where you will find further information:

– Google Analytics cookies

https://tools.google.com/dlpage/gaoptout

For “Social Network” cookies

We use the Facebook, Twitter, Pinterest, Google+ and LinkedIn sharing buttons.

To manage your data on Facebook

https://www.facebook.com/help/cookies/

To manage your data on Twitter

https://support.twitter.com/articles/20170518-utilisation-des-cookies-et-des-technologies-similaires-par-twitter

To manage your data on Pinterest

https://policy.pinterest.com/fr/cookies

To manage your data on Google+

https://policies.google.com/privacy?hl=fr#infochoices

To manage your Linkedin data

https://www.linkedin.com/legal/cookie-policy

Deactivating these cookies therefore prevents any interaction with social networks.

For advertising cookies

We use the Doubleclick and SmartAdserver platforms to manage advertising displays on our websites.

To manage Doubleclick cookies

https://www.google.com/settings/u/0/ads/authenticated

To manage SmartAdserver cookies

http://www.smartadserver.fr/privacy-policy

We also use the Ligatus platform to offer articles based on popularity and your interests, as well as sponsored articles.

Find out more about interest-based targeting

http://www.youronlinechoices.com/fr/a-propos-de-la-publicite-comportementale/

To deactivate this targeting technology

https://www.ligatus.com/fr/privacy-policy

You can also log on tohttp://youronlinechoices.com, the website of the European Digital Advertising Alliance (EDAA), an association of digital advertising professionals managed in France by the Interactive Advertising Bureau France.

This European platform is shared by hundreds of Internet advertising professionals and constitutes a centralized interface enabling you to express your refusal or acceptance of the cookies used by these companies to adapt the advertising likely to be displayed on your terminal to your browsing information:

http://www.youronlinechoices.com/fr/controler-ses-cookies/.

Lastly, certain cookies are placed by third-party service providers for the purposes of personalized advertising. You can also click on the following links to find out more about their practices and exercise your choices:

– Rubicon Cookies

http://www.rubiconproject.com/privacy/consumer-online-profile-and-opt-out/

– DoubleClick for Publisher cookies

https://www.google.com/settings/u/0/ads/authenticated

– AppNexus cookies

http://appnexus.com/en/company/platform-privacy-policy-fr

– Cookie weborama

https://weborama.com/fr/respect-de-la-vie-privee/

– Cookie Index Exchange

http://www.indexexchange.com/privacy/