The Club

Personal Data Protection Policy

Personal Data Protection Policy

The purpose of this Personal Data Protection Policy is to inform you of the processing of your personal data when you browse the cinnk.com website, published by the company CINNK SAS (the “Site“).

We want you to understand the nature of the personal information we collect, how we use it, with whom we share it, how we strive to protect it, how you can access and / or correct it and, finally, how Contact us.

The purpose of this document is also to provide you with all the information required by article 32 of the Data Protection Act and by article 13 of EU Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 relating to the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR“).

Finally, we draw your attention to the fact that we may need to make changes to this document, in particular to comply with any new regulations or to adapt it to our practices.

Article 1 – Data controller

The Personal Data collected on the Site is subject to computer data processing, the manager of which is CINNK SAS, S.A.S with a capital of 1,000 euros, whose head office is located at 23/25 Rue Jean-Jacques Rousseau, 75001 Paris.

Article 2 – Personal data that may be collected on the Site

The notion of Personal Data refers to any information relating to an identified or identifiable natural person.

CINNK SAS collects and processes the following personal data:

  • By subscribing to the Newsletter : identification data such as the User’s first name and email address.
  • By browsing our Site : the navigation data such as the IP address and the indications in terms of communication which are made available as a result of the use of your computer are collected automatically … These data are only used for the relative purposes settlement of disputes. In addition, statistical data may be collected during your visit and be used (number of pages viewed, number of site visits, etc.).
    The required fields must be filled in, otherwise your request cannot be processed by CINNK SAS.

Article 3 – Purposes of the processing of personal data and legal bases

Your Data is processed by CINNK SAS to enable you to benefit from the services offered by the Site. The data collected, the processing applied to them as well as the list of partners are presented in the “I refine my preferences” tab.

If you expressly accept your data, your data may also be used by CINNK SAS for:

  • Send you newsletters by email
  • Send you commercial offers by email
  • Evaluate, understand and report on how you use the service.
  • Subsequently send advertisements and / or personalized content in other contexts
  • Select and distribute content for you, then evaluate their distribution as well as their effectivenes

The legal basis for this processing is consent. These treatments are optional and only apply if you expressly agree to them.

Your data is also processed by CINNK SAS for:

  • Respond to your complaints: the legal basis for this processing is legitimate interest
  • Manage requests to exercise people’s rights (right of access, rectification, erasure, opposition and portability): the legal basis for this processing is the legal obligation
  • In the event of a dispute, justify compliance with our legal and regulatory obligations : the legal basis for this processing is the legal obligation

Article 4 – Recipients or categories of recipients of Personal Data

The recipients of the personal data collected are the members of the marketing department of CINNK SAS.

CINNK SAS may also disclose your Personal Data when such disclosure is necessary to :

  • Comply with the law (or a subpoena or court order);
  • Comply with legitimate requests from public and government authorities;
  • Prevent a crime or carry out an investigation, for example in the event of fraud or identity theft;
  • Protect the rights, property or safety of CINNK SAS, Users or third parties.

Your personal data may, where appropriate, be transmitted to subcontractor companies to which CINNK SAS may use in the context of the performance of the services. CINNK SAS ensures compliance with data protection requirements for all of its subcontractors.

Article 5 – Transfer of your data to a country outside the European Union

It is understood by data transfer, any communication, copy or movement of personal data intended to be processed in a third country or any data to which a third party located outside France may have access.

In the event that your data is transferred to our partners located outside the European Union, the controller guarantees:

  • Have obtained all the necessary authorizations from the competent authority to carry out said transfer;
  • Have framed this transfer by the standard contractual clauses of the European Commission or by internal company rules (Binding Corporate Rules) or ad hoc contractual clauses which the CNIL has previously recognized as guaranteeing a sufficient level of life protection privacy and fundamental human rights.

Article 6 – Rights of individuals

You have the right to access, rectify, erase and portability data concerning you. You can also request the limitation of the processing of data concerning you or object to this processing. You have the right to communicate to CINNK SAS your instructions relating to the fate of personal data concerning you in the event of death.

Your rights can be exercised with the Data Protection Officer of CINNK SAS whose contact details are indicated in this Policy.

We reserve the right to require payment of “reasonable charges” related to the administrative costs incurred in providing the information if your request is manifestly unfounded or excessive. We will do our best to respond to your requests within the timeframe required by the GDPR.

In order to protect your privacy and ensure your security, we will also take reasonable steps to verify your identity before giving you access to your personal information or correcting, modifying or deleting your subscriptions. Any request may be accompanied by a copy of your identity card.

You can, at any time and free of charge, withdraw your consent to receive newsletters / promotional offers:

  • By clicking on the link proposing to unsubscribe from the newsletter affixed to each sending of emails
  • By Contacting CINNK SAS at [email protected]
    Unsubscribing will stop sending new emails.

If your rights are not respected, you can lodge a complaint with the CNIL.

Article 7 – Data security and confidentiality

We implement organizational and technical security measures designed to guarantee the confidentiality and integrity of your personal data. As such, the administrative, organizational, technical and physical precautions are intended to protect your personal data from loss, theft, abuse of use, unauthorized access, unauthorized transmission, from any undue modification or destruction.

In all cases, the data controller will take security measures appropriate to the nature of the data collected.

The data collected is stored confidentially and protected at a high level of security. The servers where this data is stored comply with the security standards currently in force. They are protected against digital attacks and physical attacks.

All the pages of the Site on which you are required to communicate personal data are secure and are in https.

However, despite our best efforts, we cannot guarantee the infallibility of this protection due to the inevitable risks that may arise during the transmission of personal data.

Article 8 – Retention period of Personal Data

CINNK SAS only keeps your Personal Data for the time necessary for the operations for which they were collected and in compliance with the regulations in force.

In general, your Personal Data are kept as long as your Personal Account remains active and then are archived in order to meet legal obligations or for evidentiary purposes or are anonymized for study purposes and statistics.

Your Personal Data collected to send you newsletters / commercial offers will be used by CINNK SAS for this purpose until the withdrawal of consent and at the latest for a period of three years from the date of collection of your consent.

The data making it possible to trace the collection of your consent are kept by CINNK SAS for a period of 5 years in order to be able, if necessary, to provide proof of your consent.

The data is deleted without delay when CINNK SAS becomes aware of the person’s death.

Certain data may be kept for an additional period for the management of complaints and / or litigation as well as to meet our legal or regulatory obligations or to respond to requests from authorized authorities.

Article 9 – Links to external sites

It is specified that certain links on the Site allow access to external sites (i-frame, banners, etc.) and give you access to third-party services (such as social networks).

This Policy only concerns information collected on the Site. As such, CINNK SAS can not be responsible for the use of your Data on these other sites.

10.1 Advertising displays :

Certain processing operations useful for advertising displays on the Site are implemented in whole or in part by third party partners (for example advertisements or sponsored links). These are responsible for the technologies used to enable the collection of data (such as identifiers contained in cookies associated with the pages visited), for advertising targeting purposes, including on other sites.

We invite you to refer to our Cookies Policy on this point.

10.2 Link to another site

The Site may also contain links to other sites or services offered by third parties.

10.3 Liability

Article 11 – Cookies

Within the framework of our Internet pages, we use cookies. These are small text files placed on your hard drive by the visited website, allowing it to record and store certain information on your computer but also on you.

They are essential for the functioning of the internet because they allow good communication between two computers. The information collected is also used to operate applications that you use on the website.

For any further information, please consult our Cookies Policy.

We have no control over how third party sites and services process your Personal Data. We do not review third party sites and services, and we are not responsible for such third party sites and services or their privacy practices. We invite you to refer to the confidentiality policies or privacy protection statement of the third-party sites or services which you access from our sites or services.