DATA PROTECTION CHARTER
UPDATED ON 12 APRIL 2022
INTRODUCTION: WELCOME TO YOUR PERSONAL DATA PROTECTION PAGE
The PRISMA MEDIA group is a news and content publisher, offering diverse products and services on various paper and digital magazine formats (known hereafter as Media). The Group also sells advertisement space visible on the different Media.
Note that the Digital Media may include applications, newsletters, websites, and/or any other digital media edited by PRISMA MEDIA.
For more information on our products and services, users can refer to the general terms and conditions of use [here]. When available, users may also refer to the General Terms and Conditions of Sale applicable to their subscribed services.
Within the framework of their activities, PRISMA MEDIA processes personal data defined by the current regulation, notably for its clients, subscribers, and users – natural legal persons who are consumers or professionals.
PRISMA MEDIA applies the current legal requirements in relation to personal data usage, notably:
– (Text in French)the General Data Protection Regulation, no. 2016/679 of 27 April 2016, the amended “Information Technology and Civil Liberties” law no 78-17 of 6 January 1978,
– The law “to instil confidence in the digital economy” (text in French) no. 2004-575 of 21 June 2004 (article L. 34-5 of the Post and Electronic Communications Code)
The Group has also implemented ways to ensure continuous improvement regarding the compliance of their activities in view of the current legal requirements.
TAB 1. MAIN POINTS: TRANSPARENCY, LEGAL RIGHTS, SECURITY, LISTENING TO YOUR NEEDS
1.1 TRANSPARENCY
Transparency through people’s information within a unique and adaptive space
This personal data protection site aims to:
– Share the main points created by PRISMA MEDIA group regarding personal data protection;
– Describe in detail the Prisma Media Connect (PMC) universes and Prismashop;
– Define the collection methods related to cookies and other trackers, as well as personal data usage relating to targeted advertisements;
– Expose the relationships that PRISMA MEDIA has with its partners and contractors;
– Explain the methods for opposing, deleting and withdrawing consent put in place by the PRISMA MEDIA group;
The contents of this site will be able to be modified at any time by the PRISMA MEDIA Group in order to take into account any changes in the current regulations, contracts, jurisprudence, services, editions or techniques. We recommend that you check the site regularly to stay up to date.
Transparency through identifying those responsible for data processing
PRISMA MEDIA group includes the PRISMA MEDIA company, as well as all of the existing and future subsidiaries in accordance with article L 233-1 of the French Commercial Code. Today, it includes the following legal entities:
● PRISMA MEDIA, a Simplified Joint Stock company with a capital of €3,000,000 listed with the Commercial Trade Register of Nanterre under the number 318 826 187, with headquarters at 13 rue Henri Barbusse, 92230 Gennevilliers;
● CERISE MEDIA, a Simplified Joint Stock Company with a capital of €39,361, listed with the Commercial Trade Register (RCS) of Nanterre under the number 507 388 155, with headquarters at 13 rue Henri Barbusse, 92230 Gennevilliers;
● UPLOAD PRODUCTIONS, Simplified Joint Stock Company with a capital of €100,000, listed with the Commercial Trade Register (RCS) of Nanterre under the number 828 034 116, with headquarters at 13 Henri Barbusse, 92230 Gennevilliers
● EDITIONS PRESSE MAGAZINE 2000, a Simplified Joint Stock Company with a capital of €217,500 listed with the Commercial Trade Register (RCS) of Nanterre under the number 302 518 659 with headquarters at 13 rue Henri Barbusse, 92230 Gennevilliers
->Within the framework of this site, whoever is responsible for processing the data will be named by the PRISMA MEDIA group, which comprises all the companies mentioned above.
Transparency through identifying processed data
PRISMA MEDIA only processes data which is adequate, relevant, and limited to what is necessary in regards to the purposes for which they are being used.
Data that is directly collected from internet users:
Declarative data: this is information that is directly collected by PRISMA MEDIA when the internet user/client creates their personal account profile, when they use a service or a paid or free service provided by PRISMA MEDIA and/or when the user consents to having their data used for advertisement campaigns in line with the article L34-5 of the Postal and Telecommunications Code, within the framework of the current regulations.
Browsing and geolocation data: PRISMA MEDIA can collect (i) browsing data from internet users through cookies, tags and any other appropriate technical methods installed on the websites, and (ii) geolocation data from mobile applications in accordance with the current regulations and notably
the methods for obtaining consent outlined by the CNIL (Commission nationale de l’informatique et des libértes), the French Information Commissioner’s Office in its recommendations.
Interactive Data: PRISMA MEDIA can collect from interactions with the user such as page openings and clicking on newsletter links or surveying activity linked to certain services. This information allows the company to adapt how they interact with the user and to understand what they might expect.
Data collected indirectly through third parties:
PRISMA MEDIA has agreements with third parties – partners which are listed under TAB 5 “PARTNERS AND THIRD-PARTY RELATIONSHIPS”, or the subsidiaries of the Vivendi group to which the PRISMA MEDIA group belongs. These agreements may include acquiring new internet users, enrichment of existing profiles and/or establishing correspondences between the collected data through diverse sources to make up consolidated profiles and/or to create advertising segments.
Predictive data:
Predictive data comes from statistical analyses on the data described below and only for strictly accepted purposes. They allow for correcting and/or enriching internet users’ profiles through extrapolation.
Transparency through a lawful basis of processing
The main lawful basis used by the PRISMA MEDIA Group to process data within the framework of their activity, in accordance with the current regulation in the articles 6 to 9 of the GDPR are as follows:
Consent: Consent is the express agreement of the person in question regarding the processing of their data. For it to be valid, the law demands it be free, clear, specific, and unequivocal. The methods for obtaining and preserving this consent are essential to data collection compliance. The internet user/client may at any time remove their consent.
The existence of a legitimate interest: The PRISMA MEDIA Group can base its data collection on a legitimate interest in processing its internet users’ and clients’ personal data. The legitimate interest in PRISMA MEDIA is linked to its business as a news and content publisher advertisement manager.
PRISMA MEDIA Group’s activities, historically based on the publication and sale of paper magazines and the marketing of associated advertising space, have been profoundly transformed by the internet and social media. Digitising publications and creating advertising space must obey a twofold requirement of digitally transforming the company’s activities and transferring/diversifying turnover. Digitisation revealed very different uses and expectations for publishers and users that are associated with the increased collection and processing of personal data.
Processing data based on a legitimate interest from the company responsible requires close attention to detail and a very rigorous methodology. The company must exercise a careful balance between its own interest as a private company and “the interests or fundamental freedoms and rights of users” and must also integrate “reasonable expectations” of these persons.
Contractual execution: The commercial relationship based on a contract often implies processing personal data stemming from the creation the contract, for example sending a magazine through the mail to a subscriber. Using the services accessible on the PRISMA MEDIA Group websites is done according to the general terms and conditions of sale, and collecting data at this stage is considered to be in accordance with the contract linking the PRISMA MEDIA Group to the User.
Legal obligation: Certain legal obligations may imply personal data processing.
Transparency through the indication of pursued end goals
The PRISMA MEDIA Group indicates within the framework of the internet users’ data collection the goals they are pursuing when processing this data, meaning their objectives, so that the user can understand the legitimacy of this data processing.
These objectives are related to the PRISMA MEDIA Group’s activities, the publishing of its publications and press services as well as advertising sales. For example, managing a paper magazine subscription (end goal) requires collecting the contact details of the subscriber, such as their name, surname address, etc.
The PRISMA MEDIA Group clarifies its end goals for its data processing when data is collected, or at another time when additional data collection is required.
1.2 EXERCISING RIGHTS
PRISMA MEDIA has assigned a data protection officer in charge of receiving and processing requests from users/customers/subscribers (Data Subjects) for the right to information, access, rectification, objection, erasure, limitation and portability.
Under the current regulations, Data Subjects may enjoy the following rights regarding the processing of their personal data:
● the right to access all of their personal data that the PRISMA MEDIA Group processes;
● the right to rectify inaccurate, incomplete, ambiguous or outdated data;
● the right to delete all of their personal data that the PRISMA MEDIA Group has processed, except data that is deemed necessary to defend the interests of the PRISMA MEDIA Group in court, or that must be conserved in accordance with legal obligations;
● the right to object to the processing of their personal data and to withdraw consent to receive information from PRISMA MEDIA Group or their partners;
● the right to portability to retrieve Data supplied or to transfer them to another service provider;
● the right to define directives regarding to what happens to their personal data after death;
● the right to lodge a complaint with the French Information Commissioner’s Office (CNIL).
All of the methods for exercising rights (objection, deletion, consent withdrawal, etc.) are available under TAB 6 “ERASURE, OBJECTION, CONSENT WITHDRAWL” for easy and direct access for internet users.
1.3 DATA SECURITY
PRIMSA MEDIA has implemented technical and organisational methods to protect Personal Data against accidental loss, destruction, deterioration, abuse, damages and illegal or unauthorised access.
As Personal Data is confidential, the PRISMA MEDIA Group limits their access to only the company’s employees or service providers who need access in order to process the data. Any person with access to personal data must strictly adhere to the confidentiality policy and will face disciplinary action or sanctions if they do not respect these obligations. When we must rely on subcontractors, service providers or when we transfer the personal data to partners, this type of communication falls under a specific contract to ensure the protection of this data.
In general, the PRISMA MEDIA Group respects all of its obligations regarding the security of personal data as stipulated by the CNIL and the French National Agency for Information Systems Security (Agence Nationale de la sécurité des systemes d’information – ANSSI).
1.4 LISTENING TO USERS’ NEEDS
The PRISMA MEDIA Group collects and processes users’ personal data to:
(i) adapt its products and services to the interests, needs, or uses of its users;
(ii) personalise and monetise its stock within the framework of advertisement campaigns on its Media based on users’ profiles and to measure the impact of these advertisement campaigns.
The PRISMA MEDIA Group has implemented a client and user loyalty policy to communicate with them while respecting the current regulations to improve their services and to adapt to the needs of their clients. The PRISMA MEDIA Group limits the number and frequency of emails, and reminds users of their ability to object to these emails. Sales canvassing is justified on a lawful basis of legitimate interest because it concerns persons who are already clients (or who were at one point) of the PRISMA MEDIA Group. This canvassing also only concerns similar products or services to those already provided by PRISMA MEDIA.
TAB 2: THE PRISMA MEDIA CONNECT UNIVERSE
Prisma Media Connect (PMC) is the unique user account offered by the PRISMA MEDIA Group to access digital services offered by their Digital Media. You can consult the description of the Prisma Media Connect account (in French) here.
2.1 The PMC Universe
On principle, access to a service offered by the Prisma Media Group on their Digital Media is subject to the creation of a PMC account.
As such, the PMC account was designed to help users subscribe to services linked to Prisma Media’s Digital Media, to create a direct link between the reader and the editorial offices and to guide their services and data.
2.2 End Goals and Lawful bases
The table below presents a synthesis of the lawful bases for processing according to the end goal:
NO |
END GOAL |
LAWFUL FOR PROCESSING |
1 | PRISMA MEDIA CONNECT account creation and management (including automatic connection authentication) | Necessary data processing when performing a contract (Article 6, §1, b of the GDPR) |
2 | Subscription and management of Services associated with the PRISMA MEDIA CONNECT User Account (push notifications, paid digital subscriptions, Media Pass, etc.) | Necessary data processing when performance a contract (Article 6, §1, b of the GDPR) |
3 | Improving Services, user experience and loyalty operations (sales canvassing through electronic channels, for goods and services similar to those already purchased/subscribed to from the controller) and sales canvassing through postal services or automated calling systems leading to human interaction and telephone calls by the PRISMA MEDIA Group and/or their partners. | Necessary data processing for the purposes of the legitimate interests pursued by the controller (Article 6, §1, f of the GDPR) |
4 | Sales canvassing through electronic channels for goods or services that have not yet been purchased by the those targeted by the PRISMA MEDIA Group and/or their partners. | Consent of the data subject (Article 6, §1, a of the GDPR) |
5 | Targeted advertisement via the user profile on the Media | Consent of the data subject (Article 6, §1, a of the GDPR) |
6 | PRISMA MEDIA CONNECT security and system maintenance | Necessary data processing for the purposes of the legitimate interests pursued by the controller (Article 6, §1, f of the GDPR) |
7 | Management of outstanding payments, pre-litigation and litigation with clients | Necessary data processing for the purposes of the legitimate interests pursued by the controller (Article 6, §1, f of the GDPR) |
Insofar as the end goals 3. “improving User experience and Services”, and 6. “Ensuring PRISMA MEDIA CONNECT security and system maintenance” are based on the lawful basis of the legitimate interest pursued by the PRISMA MEDIA Group, these have been subjected to a specific study to balance PRISMA MEDIA Group’s and internet users’ interests.
PRISMA MEDIA’S INTERESTS | LEGITIMACY OF THE INTEREST | CONSEQUENCES FOR PERSONS |
END GOAL 3: Improving services and users experience on PMC, loyalty and sales canvassing operations through the post or automated calls leading to human interaction and phone calls | ||
Getting to know clients by:
– obtaining their feedback to improve users’experience by adapting to their needs, mainly through developing new functionalities; – carrying out loyalty operations by sending pertinent emails to propose to users PRISMA MEDIA products and services that correspond to their interests; – carrying out sales canvassing campaigns by sending physical mail and/or telephone calls by the PRISMA MEDIA Group or its partners. |
Data is processed in compliance with the CNIL’s commercial management reference framework | Improving PMC’s services and user experience: When creating a PMC account, data processing which aims to improve its services and user experience constitutes a reasonable expectation for Clients. In order to strengthen these reasonable expectations, the PRISMA MEDIA group informs its users of its data processing in the information notices and in these Policy Guidelines.
In view of the above, the legitimate interest of the PRISMA MEDIA group to improve its services and user experience does not infringe on the fundamental rights and freedoms of the users. Sales canvassing for similar products and services by PRISMA MEDIA: The data subjects who have subscribed or purchased products can reasonably expect that their data will be processed by the PRISMA MEDIA Group in order to send them sales solicitations for any similar product or service according to the provisions described in TAB 1 paragraph 1.4. This data processing should not surprise clients in the methods in which it is carried out or in the consequences of the processing insofar as these operations can be reasonably expected. Sales canvassing operations through the postal service and/or telephone calls by the PRISMA MEDIA Group or their partners: The list of partners who have access to data files is accessible on TAB 5 paragraph 5.3. Canvassing by post or telephone is possible provided that the persons have been informed, at the time of collection, of the use of their data for canvassing purposes and are able to object to this use in a simple and free manner. Provided that: – Any person has the ability to object at any time to the processing in a simple manner using a clickable link in the email and are thus in control of their data and can exercise their rights. – No sensitive data which is defined in the current regulation is collected or used for processing to improve services and user experience. |
END GOAL 6: PRISMA MEDIA CONNECT Safety and Maintenance | ||
Performing corrective and evolutionary
maintenance to ensure PMC’s security |
Ensuring the security of PMC’s systems and of the information contained with them. As such, the PRISMA MEDIA Group does not authorise access to data during maintenance operations, unless it is necessary to resolve anomalies. It is specified that this potential access will only be incidental, and no other operations will be carried out on the data during this maintenance procedure. | This processing does not qualify as intrusive in the individual sphere of users, and it is meant to reinforce the security of their data. |
END GOAL 7: Management of outstanding payments, pre-litigations, and litigations with clients | ||
Establishing the proof of a right or a contract, for example in case of a pre- litigation or litigation with clients. | Interest is compliant with the current legislation => determined in a clear, precise and real manner. | Only data that is necessary to manage outstanding payments will be processed (data linked to sales relations). Processing operations aiming to manage outstanding payments and litigations constitute reasonable expectations for clients. The present Guidelines informs Users of the potential processing of their Data for this end goal.
The CNIL’s reference document regarding sales management indicates that managing pre- litigations and litigations are based on a legitimate interest for the organisation. Therefore, it appears that the legitimate interest of PRISMA MEDIA to manage its unpaid invoices and potential disputes with its customers does not infringe on the fundamental rights and freedoms of its customers. |
2.3 Data collected and associated retention periods
It is specified that only the e-mail address of the Users is necessary for the creation of the PMC Account. All other data on the form is optional.
By way of derogation, the subscription to certain services may entail, in compliance with the principle of minimisation, the collection of some necessary data regarding this service. Where applicable, this data will be processed in the performance of a contract or on the basis of your
consent.
The PRISMA MEDIA Group saves all Personal Data for the duration required to carry out this end goal.
=> PLEASE NOTE: All of the data processed by the PRISMA MEDIA Group (apart from browsing/geolocation and predictive data) and belonging to a physical person is available in the user’s profile: this is the PMC user profile data.
The table below presents the categories of processed data, the relevant data regarding the end goal, the source of the data and the relevant retention period.
The rules for storage below are defined, except when a legal obligation stipulates that certain Data is stored for a longer duration.
At the end of the retention periods defined below, the PRISMA MEDIA Group will either delete the Data, irreversibly anonymise the data which renders it impossible to match it with a physical person in order to keep only the information necessary for analysis and statistical studies.
All user contributions published on the Media, for example in debate spaces, recipe comments, or any other contribution, will be kept after the end of the retention period while ensuring the anonymity of the contributor.
DATA CATEGORIES | DETAILS OF THE COLLECTED | SOURCE | RELATED END GOALS | RETENTION PERIOD |
Identification data | Email address | Direct collection from theUser by the PRISMA MEDIA
Group or indirect collection via the PRISMA MEDIA Group partners |
End Goal 1: Creating and managing the PRISMA MEDIA CONNECT Account | Maximum duration of 3 years starting from the last connection to the account, unless the user uses or has used one of the PRISMA MEDIA CONNECT’s services, in which case the application duration will start from the date of use of the relevant service |
Identification and
contact data |
Name, First name, Nickname, Date of birth, Gender, Email address, Phone number, Postal address, All User Contributions when using the services | Direct collection from the User or indirect collection via the PRISMA MEDIA Group’s partners | End Goal 2: Subscription and management of specific and intersectional Services associated with the PRISMA MEDIA CONNECT user account
End Goal 3: Improving Services Sales canvassing and building loyalty End Goal 4: sales canvassing through the post |
|
Connection data | Username, Authentication information, Date of registration to a Service, Date of creation of PRISMA MEDIA CONNECT Account, Date of last activity, Date of validation of the Terms and Conditions and the Guidelines | Direct collection from the User in the context of the use of their account | End Goal 6: Ensure the security and maintenance of PRISMA MEDIA CONNECT
End Goal 2: Subscription and management of specific and intersectional Services associated with the PRISMA MEDIA CONNECT user account |
6 months starting from the deletion of the Account |
Information on the
Services subscribed to |
Types of services used, Date of subscription to the service, Date of last activity on the service, Subscriptions subscribed to, Dates of subscriptions subscribed to, Service usage statistics | Data generated by the User’s activity on the Media of the PRISMA MEDIA Group | End Goal 2: Subscription and management of specific and intersectional Services associated with the PRISMA MEDIA CONNECT user account
End Goal 3: Improving the Services and user experience |
Duration of 3 years starting from the last time a service was used or last expression of interest |
All data (including
Behavioural Tracking via cookies and Geolocation (only for mobile applications)) |
Name, First name, Nickname, Date of birth, Gender, Email address, Phone number, Postal address, All User Contributions when using the services Types of services used, Date of subscription to the service, Date of last activity on the service, Subscriptions subscribed to, Dates of subscriptions subscribed to, Service usage statistics Username, Authentication information, Date of registration to a Service, Date of creation of PRISMA CONNECT Account, Date of last activity, Date of validation of the Terms and Conditions and the Guidelines. | – Direct collection from the User by the PRISMA MEDIA Group or indirect collection via the PRISMA MEDIA Group’s partners
– Data generated by the User’s activity on PRISMA MEDIA Group’s Media |
End Goal 5: Targeted advertisement via the user profile on the Media | Maximum duration of 3 years starting from the last connection to the account, unless the user uses or has used one of the PRISMA MEDIA CONNECT’s services, in which case the application duration will start from the date of use of the relevant service |
Browsing information (IP address, sites visited, pages/content visited, etc.), Geolocation data. | 6 months starting from the deletion of the Account |
Please note: for paid services, a user is susceptible to save bank details. These are collected and processed within the framework of subscriptions by the payment service providers, those responsible for the processing of bank details, who may retain them according to nature of the order (i.e. staggered payments) and if the user wishes. The confidentiality policies are made available by the PRISMA MEDIA Group during the entire payment process. When the banking Data is stored by the PRISMA MEDIA Group, it is done so partially, rendering any other payment impossible, and are used only to track and identify an order.
2.4 PMC account Connection Rules
Access to the PMC account is secured through either a login (email address) and a password, or through by generating a connection link known as a ‘magic link’ sent to the user for a one-time, limited duration use, allowing them to safely connect to their account.
Internet users can connect to their PMC account using accounts that they hold for certain third party services such as Facebook, Google or Twitter according to the details in TAB 5, Paragraph 5.6.
To facilitate user navigation while ensuring the security of its data, the PRISMA MEDIA Group has set up three authentication rules: weak, normal, or strong depending on how the user use’s their account.
The weak and normal authentication is applicable for a period of six (6) months and tacitly renewable for the same periods in case the user is active and connected to his/her account on one of the Supports of PRISMA MEDIA during the last six (6) months.
Strong authentication is applicable for a period of one (1) hour, after which the user must move to a normal authentication unless they enter their email address and password again. Only the strong authentication allows the user to modify their personal information and to delete their PMC account. They will also have access, following a strong authentication, to subscribe to all of PMC’s paid services.
2.5 Exercising rights
Within the framework of PRISMA MEDIA CONNECT, we invite you to consult the table below to familiarise yourself with the applicable rights for each end goal:
NO | END GOAL | APPLICABLE RIGHTS |
1 | Creating and managing a User Account | ● Right of erasure
● Right to restrict processing ● Right of portability ● Right of rectification ● Right of access |
2 | Subscription and management of specific and intersectional Services associated with the User Account | ● Right of erasure
● Right to restrict processing ● Right of rectification ● Right of portability ● Right of access ● Right to withdraw consent |
3 | Improving Services | ● Right of erasure
● Right to restrict processing ● Right of portability ● Right of access ● Right of rectification ● Right to object |
4 | Sales canvassing through profiling | ● Right of erasure
● Right to restrict processing ● Right of rectification ● Right of portability ● Right of access ● Right to withdraw consent |
5 | Targeted advertisement through the user profile on the Media | ● Right of access
● Right to withdraw consent |
6 | Ensuring the security and maintenance of information systems | ● Right of erasure
● Right to restrict processing ● Right of portability ● Right of access ● Right of rectification ● Right to object |
Internet users may refer to TAB 6 for erasure, objection and to withdraw consent.
TAB 3: PRISMASHOP PRODUCTS AND SERVICES UNIVERSE
3.1 Prismashop Universe
Prismashop is the shop for managing one-off purchases and subscriptions for the PRISMA MEDIA Group. The Group has a website offering a number of products (i.e. press subscriptions). The Group has a website offering a number of products (i.e. press subscriptions). PRISMA MEDIA Group collects personal data from PRISMASHOP users.
3.2 End Goals and Lawful Bases
The table below presents a synthesis of the lawful bases for processing according to the end goal:
NO | END GOAL LAWFUL BASIS FOR PROCESSING | LAWFUL BASIS FOR PROCESSING |
1 | Creation and management of the User Account on Prismashop (including automatic user authentication) |
Necessary processing to perform a contract (Article 6 §1, b of the GDPR) |
2 | Customer relationship management | Necessary processing to perform a contract
(Article 6 §1, b of the GDPR) |
3 | Management of outstanding payments, pre-litigation and litigation with clients |
Necessary processing to perform a contract (Article 6 §1, b of the GDPR) |
4 | Personalised sales canvassing based on the user’s profile through SMS and email by the PRISMA MEDIA Group or their partners. | Consent from the relevant person (Article 6, §1, a of the GDPR), |
5 | Improving Services, user experience and loyalty operations (sales canvassing through email for goods and services similar to those already purchases/subscribed to from the controller) and sales canvassing through the post and by telephone by the PRISMA MEDIA Group or their partners. | Necessary data processing for the purposes of the legitimate interests pursued by the controller (Article 6, §1, f of the GDPR) |
6 | Security and maintenance of Prismashop. | Necessary data processing for the purposes of the legitimate interests pursued by the controller (Article 6, §1, f of the GDPR) |
Processing identified as necessary for a legitimate interest by Prisma Media were part of a specific study to find a balance between PRISMA MEDIA’s interests and the interests of the data subjects. The purpose of this balancing is to ensure that the interests pursued by PRISMA MEDIA are legitimate and that they are balanced with the rights and interests of the Prismashop clients and Users. The table below synthesises the study carried out for each of the end goals.
3.3. Interaction data: PRISMA MEDIA may also process data on interactions between you and our company: opening or linking newsletters that we send, clicks on the links in the newsletters that we send. This information allows us to adapt the discussions we have with you.
As these Services are offered exclusively via your PRISMA CONNECT Account, we invite you to consult the PRISMA CONNECT Personal Data Protection Charter for further details.
ARTICLE 4 – WHO RECEIVES THE PERSONAL DATA?
The Data are intended for PRISMA MEDIA.
They may also be sent to service providers appointed by PRISMA MEDIA in connection with its activities and to provide its Services.
In the event that Data is transferred outside the European Union, PRISMA MEDIA shall inform you of such transfers and take the necessary measures to supervise them in accordance with the regulations in force (by signing the standard Contractual Clauses of the European Commission) and ensure the confidentiality and security of your Data.
Subject to your consent, you may also receive communications and commercial offers relating to products and/or services provided by PRISMA MEDIA or its partners, in particular member companies of the Vivendi group, advertisers, advertising agencies and advertising agencies. The list of partners, and their privacy policy, is available here.
PRISMA MEDIA undertakes to contractually supervise any transmission of Data to partners so that they comply with the regulations in force. It is specified that the partners will act as independent data controller and that, as such, PRISMA MEDIA is not responsible for the processing of your Data implemented by its partners or the Data transmitted.
To avoid receiving commercial offers from our partners, you can at any time click on the administration interface provided for this purpose via the bottom-of-page link “configure your cookies”.
You may also withdraw your consent at any time by exercising your rights under the conditions defined in Article 8 of this Charter.
Furthermore, in accordance with the regulations in force, your Data may be sent to the competent authorities on request.
ARTICLE 5 – WHAT IS THE RETENTION PERIOD FOR PERSONAL DATA?
Depending on the purpose of the processing, the retention period for Personal Data may vary. Unless there are mandatory legal provisions, PRISMA MEDIA shall retain the Personal Data for the period necessary to achieve the intended purpose.
- Personal Data will thus be retained for the period during which you use our Services, and deleted no later than 3 (three) years from our last contact, unless there is anonymisation or a legal obligation to retain certain data for a longer period.
- Site login data shall be retained for a maximum of 6 (six) months.
The above retention rules are defined unless there is a legal obligation to retain certain Data for a longer period.
ARTICLE 6 – WHAT IS PRISMA MEDIA’S POLICY ON COOKIES AND SIMILAR IDENTIFICATION TECHNOLOGIES?
When you visit our Sites, you may access the content of the Sites by accepting PRISMA MEDIA’s use of cookies or other trackers, or by subscribing to a paid subscription giving you access to advertising-free content via a PRISMA CONNECT account.
PRISMA MEDIA shall not use any Cookies or other trackers before Users being offered a choice in this regard.
1- Acceptance of Cookies and other trackers
PRISMA MEDIA, which is part of the Vivendi group, allows the filing of third-party identifiers used by Vivendi group companies such as Canal+, Dailymotion, Gameloft, Editis and Vivendi Village. These companies also use identifiers on their sites and are likely to share them with PRISMA MEDIA. PRISMA MEDIA may also share identifiers with Vivendi group companies. For an exhaustive and up-to-date list of entities belonging to the Vivendi Group, please visit https://www.vivendi.com/notre-groupe/a-propos/
When you choose to access the content free of charge via acceptance of Cookies, you consent to PRISMA MEDIA and its partners using cookies or similar technologies and processing your navigation and behavioural data (IP address, pages visited or dates and times of viewing) in order to help us improve your navigation and make it more interesting, and which allow us to:
- Personalise advertising
- Personalise your content
- Develop and improve our products and services
PRISMA MEDIA may use identification technologies other than cookies that perform the same role as described in this Article in mobile environments where cookies do not work. These solutions can be SDK (Software Development Kit) or Local Storage or any other suitable solution.
Our partners may also combine the information collected via cookies with other information that you have provided to them or that they have collected as processors. These partners may also be required to advertise on the Sites and may use their own cookies. PRISMA MEDIA has no access to or control over the cookies that these companies may use. Here you will find a list of partners with whom we have established a contractual relationship and who place cookies on your device.
If you accept the Cookies, your consent will be recorded for a period of 6 months.
Your consent to the use of Cookies and other trackers will apply to all PRISMA MEDIA Sites, as well as to Newsletters subscribed by Users.
The Sites of the PRISMA MEDIA brands concerned by the use of Cookies shall be as follows:
- Business Insider;
- Ça m’intéresse;
- Capital;
- CesoirTv;
- Cuisine Actuelle;
- Femme Actuelle;
- Femme Actuelle Senior;
- Femme Actuelle Le Mag;
- Gala;
- Gentside;
- Geo;
- Harvard Business Review;
- Neon;
- Oh My Mag;
- Tele Loisirs;
- TV 2 weeks;
However, it is specified that acceptance of the use of advertising identifiers on the PRISMA MEDIA Mobile Applications shall be on an Application by Application basis.
You can access the consent configuration interface via the Sites at any time to:
- configure your preferences point by point: You may refuse or selectively accept the installation of behavioural analysis, geolocation and/or audience measurement cookies and/or the installation of cookies by PRISMA MEDIA’s partners by configuring your settings on your cookie management account;
- access the list of our partners authorised to place cookies on our sites, as well as a link to their privacy policy.
PRISMA MEDIA may combine the information collected by cookies according to your choice with information collected by any other means (in a registration form, in a newsletter registration, etc.) for the accepted purposes, and in particular, if you have a prisma connect account, we may combine the information collected by cookies with the personal data from your account.
2- Refusal of cookies and other trackers
If you do not wish to accept Cookies to access the content of all the Sites, you may subscribe to the paid subscription offer via your PRISMA CONNECT account. The terms and conditions of the subscription are defined in the General Terms and Conditions of Sale.
Where applicable, you may browse the websites of the PRISMA MEDIA brands as described above without any advertising.
Conversely, on the PRISMA MEDIA Mobile Applications, the subscription offering is offered Application by Application.
When your subscription expires, you will again be offered the choice between the two content access offers.
3 – Cookies exempt from consent
In any event, certain Cookies and other trackers will be used by PRISMA MEDIA regardless of the consent of internet users. These are exempt cookies as recognised by Article 82 of the French Data Protection Act, as well as CNIL Guidelines no. 2020-091 of 17 September 2020. These are:
- navigation cookies, which facilitate navigation on the Sites or which are necessary for the provision of the Services that you order (e.g. session cookies, or flash cookies enabling a media reader to operate when necessary to the operation of the Services that you order, etc.);
- cookies analytics (audience measurement) to obtain anonymous traffic statistics. PRISMA MEDIA uses these cookies in order to optimise its ergonomics, navigation and content, to detect navigation problems that may occur on the Sites, to improve their performance and functionality, to the exclusion of any other use; or to improve the Services. If these cookies are deactivated, we will not be able to analyse the traffic on the PRISMA MEDIA Sites. You will find the list of analytics cookies used on the Sites via the PRISMA MEDIA CMP. If you wish to object to the use of analytics cookies, you can contact dpo@prismamedia.com with the subject line “opposition cookies analytics”.
4 – Cookies on institutional and e-commerce websites
The institutional site (https://www.prismamedia.com) and the e-commerce site (https://www.prismashop.fr) of PRISMA MEDIA use cookies under conditions separate from those described in this Article 6.
The institutional site uses cookies and processes your navigation and behavioural data for the purpose of the proper functioning of the site as well as for statistical and audience measurement purposes. As for the e-commerce site, it uses cookies to ensure the proper functioning of the service, to improve and develop our products and services, and to personalise your user experience on the site via self-promotion and personalised content.
The information collected by cookies on institutional and e-commerce sites is only shared with PRISMA MEDIA partners acting on its behalf. PRISMA MEDIA is committed to contractually supervising the transmission of this information to its partners in order to ensure the implementation of the necessary measures to ensure the protection and security of the information processed.
On these sites, you have the choice of accepting cookies, configuring their use depending on the intended purposes, or continuing on the site without accepting cookies. The choice regarding the use of cookies will apply only on the site on which it was made and will be recorded for a period of 6 months. If cookies are refused, only exempt cookies as described in article 6.3 may be used by PRISMA MEDIA on these sites.
5 – Mobile applications
However, it is specified that acceptance of the use of advertising identifiers on the PRISMA MEDIA Mobile Applications shall be on an Application by Application basis.
You can access the consent configuration interface via the Sites at any time to:
- configure your preferences point by point: You may refuse or selectively accept the installation of behavioural analysis, geolocation and/or audience measurement cookies and/or the installation of cookies by PRISMA MEDIA’s partners.
- access the list of our partners authorised to place cookies on our sites, as well as a link to their privacy policy.
Certain PRISMA MEDIA Mobile Applications allow your geolocation data to be collected subject to your authorisation. When you are connected to the Application and have activated the option, we collect information about your location in order to offer you advertisements and services based on your geographical position.
If the geolocation option in the background is activated, we also collect this information in the event that the Application is closed and not used.
If you do not want us to make such use of your location data, you should deactivate the use of geolocation in the background or, more generally, object to the use of your geolocation data in the consent configuration interface as well as by deactivating the geolocation function in the settings of your device.
ARTICLE 7 – WHAT SECURITY MEASURES?
PRISMA MEDIA has put in place technical and organisational measures to protect Personal Data against accidental loss, destruction, damage, abuse, damage and unauthorised or illegal access.
As Personal Data is confidential, PRISMA MEDIA limits access solely to the company’s employees or service providers who need them in connection with the processing.
All persons having access to the Personal Data are bound by a duty of confidentiality and risk disciplinary and/or other sanctions if they do not comply with these obligations.
When we use subcontractors, service providers or transmit Personal Data to partners, this communication is covered by a contract to ensure the protection of this information.
ARTICLE 8 – WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
Under current regulations, you have the following rights with regard to the processing of your Data:
- A right of access to all the Data that we process about you;
- A right to rectify inaccurate, incomplete, ambiguous or obsolete Data;
- A right to erasure of all Data that we process about you, with the exception of Data necessary to defend our interests in legal proceedings or that we must retain in accordance with our legal obligations;
- A right to object to the processing of your Data and to withdraw your consent to receive information from us (in particular marketing messages);
- A right to portability in order to retrieve the Data you have provided to us or to transfer them to another service provider;
- The right to set guidelines on what is to be done with your Data after your death;
- The right to complain to the Commission Nationale de l’Informatique et des Libertés (CNIL), whose contact details are available at: https://www.cnil.fr/fr/vous-souhaitez-contacter-la-cnil).
To stop receiving messages from PRISMA MEDIA, you can also click on the unsubscribe link in each of our messages.
If you have any questions or wish to exercise your rights, simply send an e-mail or letter to the following address: dpo@prismamedia.com.
dpo@prismamedia.com OR PRISMA MEDIA, Data Protection Officer, 13, rue Henri Barbusse – 92230 Gennevilliers.
When you wish to exercise a right, your requests must be in writing and signed and accompanied by a photocopy of an identity document bearing your signature. The request must specify the address to which the response must be sent. PRISMA MEDIA shall have a period of 1 (one) month in which to respond following receipt of your request. However, this period may be extended by two months given the degree of complexity and number of applications sent to PRISMA MEDIA. In this event, we will inform you of this extension and the reasons for it.
ARTICLE 9 – WHAT ABOUT THE USE OF MY DATA VIA SOCIAL NETWORKS?
You can join our Instragram accounts, Pinterest, our Facebook pages, from our Site and follow our news via these. The only data that PRISMA MEDIA may collect is anonymous and processed for purely statistical purposes (in particular to monitor the number of subscribers who follow these accounts).
PRISMA MEDIA is not responsible for the processing of Personal Data that may be undertaken by these social networks. In order to know your rights with regard to these social networks and configure your options in order to protect your confidentiality, you should consult the privacy policy of each of them:
- Instagram privacy policy: available here
- Facebook Privacy Policy: available here
- Pinterest Privacy Policy: available here
Log in via your Facebook or Twitter account
You may log in to some of our sites or applications with your Facebook or Twitter account. When you connect to our sites with your Facebook or Twitter account, PRISMA MEDIA may have access to certain information that you have sent to these social networks. You will be asked for permission to access your profile data and share your activities with Facebook and Twitter and informed about the data used and how it will be used and shared. On the other hand, any additional information we may request will not be sent to Facebook or Twitter.