1. Who is responsible for processing?
EPTIMUM, a simplified joint-stock company with a capital of 510 003 €, whose registered office is located at 49 rue de la Vanne, 92120 Montrouge, is the publisher of the entelechargement.com online store which offers all ranges of professional and consumer software.

This Privacy Policy sets out Eptimum's commitments regarding the protection of your personal data in your capacity as a customer or Internet user, and as a user of the services. It sets out the terms and conditions for the collection and use of personal data concerning you, and your rights in this respect.

The company Eptimum complies with the French law "Informatique et Libertés" n° 78 of 6 January 1978 as amended, the law for "Confidence and the Digital Economy" n° 2004 - 575 of 21 June 2004 as well as Regulation 2016/679 of 27 April 2016.

The company Eptimum has appointed a Data Protection Officer (Délégué à la protection des données) in charge of ensuring the correct application of the law and the respect of your rights of access, rectification, opposition, deletion, limitation and portability in accordance with the said law (dpo@eptimum.com).

Eptimum's Privacy Policy applies in addition to the General Terms and Conditions of Sale.
2. What personal data is collected on our sites and why?
As Data Controller under the French Data Protection Act and Regulation 2016/679 of 27 April 2016, Eptimum is responsible for the personal data it collects.

The data is collected in order to allow you, as a customer, prospect or simple user of our services, to receive personalized information, to manage your orders, to offer you adapted commercial offers, and if necessary to make you benefit from offers from our partners. This data also allows our services to administer and improve our marketing activities and services to our customers.

When collecting your personal data, you are informed of the compulsory nature of the information requested, in order to be able to benefit from a service, or of its optional nature, as well as of the consequences of not communicating any data. You are also informed of the use that Eptimum will make of your data, and of your right to access, rectify, oppose, delete, portability of the data, to limit processing, and to know the fate of your data after death.

Declarative data : The company Eptimum collects the data necessary to use the service of your choice, or to manage your order. The data collected on this occasion may be: your first and last name, your postal address, your e-mail address, your telephone number.

You may be offered the opportunity to receive commercial offers from Eptimum or its partners. In accordance with the law for "Confidence in the digital economy", you must clearly express your consent by ticking a box confirming your agreement, where applicable. You will of course be able to withdraw your consent at any time by exercising your rights of opposition, deletion or limitation. However, you will not be able to question the lawfulness of the processing operation prior to withdrawal.

All this data is stored in our customer database, in order to be able to communicate with you and propose offers adapted to your needs.

Behavioural data : You may be asked to respond to online surveys offered by Eptimum because you are a customer and user of products or services. These surveys are anonymous. However, we may ask for your consent to keep, associated with your customer account, some declarative behavioural data. In this case, with your consent, we will keep this data. You are then informed of your rights of access, rectification, deletion and opposition, and of the means to exercise them.

We are also likely to keep track of the interaction events that occur between you and Eptimum's services (page loads, button clicks, click rates on newsletters, banners, etc.) in order to offer you offers adapted to your wishes, and generally improve our services according to our customers' expectations. In this case, with your consent, we keep these data. You are then informed of your rights of access, rectification, opposition and deletion, the portability of the data, the limitation of processing and the means of exercising them.

Cookies : A cookie is a small text file, stored on your computer's hard drive at the request of the server managing the website visited. It contains information on the navigation carried out on the pages of this site and makes it easier to use the site on your next visit. The information collected by a cookie can only be read by its issuer. You can oppose the installation of cookies, but in this case you risk having a degraded access to the services offered, or even the impossibility to place an order.

Data not collected directly from you : In some cases, Personal Information about you may have been collected from third parties. For example, Eptimum may collect Personal Information from these partners. These sources are non-public. If necessary, we will not fail to communicate to you all information on the processing as well as any useful information regarding the exercise of your rights of opposition, deletion, limitation, access, rectification and portability.
3. What uses does Eptimum make of your personal data?
Declarative data

Declarative data is necessary to record and manage your orders, or to use the services offered by Eptimum's websites.

The data concerning your centres of interest or the composition of your household can enable the company Eptimum to make proposals adapted to your needs.

Your e-mail address may be used under the following conditions :

  • If you are an Eptimum customer, Eptimum may send you offers of products similar to those you have already ordered.
  • When your e-mail address is collected, or at a later date, you may be asked to tick a box confirming your agreement to receive commercial offers from Eptimum. If you accept by ticking this box, Eptimum may send you offers of the products it markets by e-mail.
  • Similarly, you may be offered to receive offers from Eptimum's partners by ticking the box provided for this purpose. If you accept, Eptimum's partners may send you commercial offers by e-mail.

In any case, you can ask to no longer receive commercial offers at your e-mail address. :

  • Or by using the unsubscribe link that you will find at the bottom of all Eptimum's commercial e-mailings.
  • Either by sending a letter to the following address: Société EPTIMUM, 49 rue de la Vanne, 92120 Montrouge.
  • Or by sending an e-mail to our DPO at the following address: dpo@eptimum.com.
  • In addition, in accordance with law no. 2014-344 of 17 March 2014 relating to consumer affairs, you can oppose telephone canvassing by registering on the national opposition list "Bloctel": https://conso.bloctel.fr.

The company Eptimum informs you nevertheless that there are exceptions. Indeed, the law allows you to be called if :

  • You're our client.
  • You have given your telephone number unequivocally: we will then be able to contact you within 3 months from the date of communication of your telephone number.


Behavioural data

During your visits to Eptimum's websites, cookies may be placed on your computer. The company Eptimum respects the recommendation of the CNIL dated 5 December 2013 concerning cookies:

  • During your first visit to a site, a banner informs you of the installation of cookies, your ability to object to them and the procedure to follow to do so.
  • This does not apply to cookies that allow you to navigate our sites and to be identified on your next visit, or to memorize your shopping cart.

In accordance with the regulations in force, behavioural data may be transmitted to the competent authorities on request.

Security of personal data

The company Eptimum implements all technical means to guarantee the security of your personal data, and to prevent any risk of loss, deterioration or misuse thereof.
4. Who are the recipients of your personal data?
The Personal Data collected is intended for the company Eptimum.

Your Personal Data will not be communicated to third parties, except in the following cases:

  • When you have given your prior consent to the sharing and/or disclosure of your Personal Information, including through the features offered by Eptimum's websites.
  • When Eptimum is required to share your Personal Information with business partners (as authorized by you), suppliers, service providers and in particular technical service providers for the purposes of providing the services, resolving problems with the operation of the services or offering advertising and promotional information in connection with the services offered by Eptimum.
  • In particular, Eptimum provides your Personal Data to third party companies to provide services on its behalf, including payment processing, data analysis, processing of direct mail campaigns, management of subscription and re-subscription information flows, hosting of services, processing of certain marketing aspects of the services.
  • The application of a law, a regulation or by virtue of a decision of a competent regulatory or judicial authority or, if necessary, in order to preserve its rights and interests, the company Eptimum may communicate your data.
  • In the event of a change of control of Eptimum or the sale of all or part of its assets, Eptimum will be authorised to transfer your Personal Data.

Eptimum does not pass on your Personal Data to third party advertisers for targeted marketing purposes unless you have given your prior consent. Please note, however, that advertisers may obtain your Personal Data from other public sources. Eptimum cannot be held liable in the same way in this respect.

On the other hand, Eptimum may use and share with third parties certain non-personal technical or aggregated data relating to your browsing on Eptimum's websites. The collection, processing and disclosure of such anonymous data is not subject to the restrictions set forth herein.
5. How long do we keep your personal data?
The length of time we retain your Personal Information may vary depending on the purpose of the collection.

Statutory obligations may require Eptimum to keep a minimum retention period. In other cases, the data concerning you will only be kept within the limits of the purpose pursued (in this case for the duration strictly necessary for the management of the commercial relationship, i.e. seven years from the end of your last purchase, or if you are not a customer, three years after the last contact on your part), or in compliance with the regulations applicable in this area.

The information stored in your terminal (e.g., cookies), or any other element used to identify you and enable their traceability, as well as raw traffic data associating an identifier, will not be kept for more than thirteen (13) months.
6. Is your personal data being transferred abroad?
In order to ensure the performance of its services and in particular the management of information flows, Eptimum may transfer, for these purposes only, your Personal Data to subcontractors located outside the European Union. In order to ensure the respect of your privacy and your Personal Data, the subcontractors concerned are signatories to the standard contractual clauses validated by the European Commission.
7. What is our cookie management policy?
Cookie management

A cookie is a text file that records information about your Internet browsing. This file, which is placed on the user's hard disk when the server site is consulted, cannot contain viruses or be executed. It is not active. Moreover, you can read, destroy or modify it. A cookie cannot be used to retrieve personal data from your hard disk, read your e-mail address or obtain personal information.

Eptimum's websites use cookies for a variety of reasons. In particular, a cookie enables us to send you personalised offers, to identify you when you access your customer account, to keep items in your shopping basket after you have logged out.

In accordance with the Ordinance of 24 August 2011 on the application of European directives on the protection of privacy on the Internet, a cookie cannot be implanted (except for legal exceptions) on your computer without your prior consent. The company Eptimum is therefore obliged to seek your prior consent, which is valid for a maximum of 13 months.

However, some cookies are exempted from the collection of this consent:

  • The sole purpose of the cookie is to enable or facilitate communication by electronic means.
  • The cookie is strictly necessary to provide an online communication service at the express request of the user.

How do you express your choices?

You have several options for managing Cookies, accepting or rejecting them. You can do this by :

  • Demonstrate your choice by setting up your web browser (a))
  • With regard to advertising cookies, use a tool published by digital advertising professionals (b));
  • With regard to analytical cookies, you can oppose them by clicking on a simple link (c)
  • With regard to the cookies issued by Eptimum, you can oppose them in accordance with the simple and accessible procedure described below (c);

Review the privacy policy of the social network you use, and thus manage the deposit of cookies from that social network (d)).

a) Setting up your browser

Most browsers accept cookies by default. However, you can choose to block these cookies or have your browser notify you when a site tries to implement a cookie on your device. In this context, we inform you that you can set your browser to refuse the implementation of cookies. Each browser is configured differently to manage cookies and your choices. It is described in the help menu of your browser, which will tell you how to change your cookie preferences.

Safari : https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=fr_FR

Opera : http://help.opera.com/Windows/10.20/fr/cookies.html

Chrome : https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en

Internet explorer : http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

FireFox : https://support.mozilla.org/fr/kb/activer-desactiver-cookies?redirectlocale=fr&redirectslug=Activer+et+d%C3%A9sactiver+les+cookies

b) Expressing your choices online to cross-industry platforms to refuse advertising cookies only

The "Youronlinechoices" Platform, offered by digital advertising professionals grouped within the European association EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France, gives you the possibility of refusing or accepting the Cookies used by its member companies to adapt to your browsing information the advertisements likely to be displayed on your device:
https://www.youronlinechoices.com/uk/your-ad-choices

Be careful, your choice will not prevent the display of ads but will block technologies that allow you to adapt ads to your interests.

c) Demonstrate your choices to the company Eptimum

When you connect to our sites, and we have not accepted the deposit of cookies in the 13 months prior to your visit, a banner appears and asks for your agreement to the deposit of cookies. With your express agreement, cookies are deposited to allow optimal access to the site. For example, cookies allow us to identify you and access your customer account. Please note, however, that whether you have accepted or refused the deposit of cookies, your choice can only be saved on the condition that you use the same browser and that you have not deleted your browsing history in the meantime.

d) By objecting directly to the issuer of this cookie in the case of analytical cookies or cookies issued by social networks:

  • Analytical Cookies

The company Eptimum uses two tools to measure the audience of its sites.

With respect to Google Analytics, if you do not want this tool to collect or use your information, you can unsubscribe from the following page:
http://tools.google.com/dlpage/gaoptout?hl=None

You can also opt-out of Google Analytics advertising features via the Network Advertising Initiative's opt-out page by clicking on the following link:
http://www.networkadvertising.org/choices/

  • Social Network Cookie

To find out the purpose and scope of data collection, processing and use by the social network(s) to which you belong, as well as your rights and possibilities for modifying the parameters for the protection of your privacy, we invite you to read their policy on the management of Cookies on their sites.

Facebook : http://www.facebook.com/about/privacy/

Google+ : http://www.google.com/intl/it/policies/privacy/

Twitter : http://twitter.com/privacy

Instagram : https://instagram.com/legal/cookies/

YouTube : https://www.youtube.com/static?template=privacy_guidelines

In order to enable you to assess the usefulness of a particular cookie to you, a presentation of the different types of cookies follows this paragraph.

Cookies - Glossary

Functionality cookies and cookies necessary for the operation of Eptimum's sites

These cookies are deposited exclusively by Eptimum and are necessary for the proper functioning of the sites you use and to access the functionalities of the sites intended to ensure your browsing comfort. They may also be used to adapt the display of our sites to the preferences of your terminal.

Analytical cookies

Our sites include analytical cookies whose purpose is to know the frequentation, use and performance of our sites, and to improve their operation and ergonomics (e.g., the pages most often consulted, visitor searches, etc.).

The company Eptimum uses Google Analytics, which collects the information necessary for the analysis described above.

Sharing cookies (social links)

To allow you to share articles and content with your friends and family or to comment on them, our sites contain sharing links to social networks (Facebook, Twitter). When you use these share buttons, a third-party cookie is installed. If you are connected to the social network when you browse our site, the share buttons allow you to link the content you view to your user account.

Advertising cookies

Our advertising agency markets the advertising space on our sites. The advertisements broadcast on our sites are likely to contain :

  • Cookies issued by the advertiser (i.e., the one on whose behalf the advertisement is broadcast) or by a third party concerned by this advertisement (audience measurement for example), and make it possible in particular to calculate the amounts owed by advertisers but also to limit the number of times you see an advertisement.
  • Cookies issued by our agency: These are cookies used to offer you advertising tailored to your interests on our sites. In particular, they are used to limit the number of times you see an advertisement.

In addition, certain cookies may be issued by intermediaries in the advertising market and follow you from one site visit to another for the display of advertising.
8. What are your rights and how do you exercise them?
Pursuant to the provisions of Articles 39 and 40 of the French Data Protection Act and European Regulation 2016/679, you may request communication of your Personal Data and demand that your Personal Data, which are inaccurate, incomplete, ambiguous, outdated, or whose collection, use, communication or storage is prohibited, be rectified, completed, updated, locked or deleted, as the case may be.

In accordance with Article 18 of the European Regulation 2016/679, you may also, if necessary, request to limit access to the processing (e.g. when the accuracy of your Personal Data is contested by you - for a period of time that allows Eptimum to verify the accuracy of your Personal Data, or when Eptimum no longer needs your Personal Data for the purpose of processing but they are still necessary for the establishment, exercise or defence of legal claims).

In accordance with Article 20 of the European Regulation 2016/679, you may also, within the limits of the technical processes used by Eptimum, request to receive your Personal Data, in a structured, commonly used and machine-readable format, and that they be transmitted to another data controller for processing carried out by means of automated processes for which you have given your consent.

For all these requests, just send an e-mail or a letter to the following address:

Company EPTIMUM
Data Protection Correspondent
49 rue de la Vanne
92120 Montrouge
dpo@eptimum.com

In accordance with the decree n°2007-451 of March 25, 2007 taken for the application of the law "Informatique & Libertés", your requests must be presented in writing and must be signed and accompanied by a photocopy of an identity document bearing your signature. The request must specify the address to which the reply should be sent. The company Eptimum will have a period of 1 (one) month to reply following receipt of your request.

For your complete information, you have the right to contact the Commission Nationale de l'Informatique et des Libertés (whose contact details can be found at https://www.cnil.fr/fr/vous-souhaitez-contacter-la-cnil) in the event that Eptimum does not respond to your request within one month of your request. If necessary, this period may be extended by two months, depending on the complexity and number of requests.