We may collect the data listed below in connection with your use of the Platform. These data are not all considered to be “personal data” under applicable law. However, we want to provide you with the most comprehensive information on all the data we process when you use this Platform.
Note that we never solicit the communication of sensitive data (or “special categories of data” as defined by law) and we ask that you do not transmit such data to us.
1.1 Information you provide us
The Platform provides access to different forms that enable you to subscribe to ANA or to buy some Content, to receive some specific information or register for events, to send us information or press releases, to apply for a job at ANA or to contact us for other reasons. You may also, on a voluntary basis, answer questionnaires, opinions or surveys that we offer in order to improve our services or your browsing experience.
When you complete one of these forms, you shall provide us with all or part of the following data depending on the nature of the form: name, surname, civility, email address, activity, company, mailing address of your company, phone number, areas of interest, subject and content of the message, acceptance or refusal to be kept informed by e-mail on new products and offers from ANA and its subsidiaries.
1.2 Information we collect when you use the Platform
During each of your visits to our Platform, we may collect the following data:
• Data about the devices, networks and platforms you use: identifier of the device you are using (IP address, Apple ID, Android ID, etc.), connection data (date, time, duration), type and version of the browser software (Internet Explorer, Safari, Mozilla Firefox, Google Chrome, etc.), type of operating system (Microsoft Windows, Apple OS, Linux, Unix, etc.).
• Data about your preferences and other actions on the Platform: interface language, reference of the user’s start page.
• Data relating to your browsing: route on the Platform’s pages and duration of consultation of certain pages, Content that you consult, searches and results of searches and generally your actions on the Site.
• Information on the reading or not of the emails we send you and on your clicks on the links contained in these emails.
The data we collect is used for the purposes and based on the legal grounds described below.
Purposes of use & Legal basis
Provide you with information about our services and answer all your questions. This processing is carried out with your consent.
Provide you with the ability to customize your preferences on the Site. This processing is carried out for the purpose of your legitimate interest and / or with your consent.
Handle and correct any incidents or errors of the Site. This processing is carried out for the purpose of our legitimate interest (ensuring the performance and security of the Platform).
For internal audits on data analysis and audience statistics. This processing is carried out for the purpose of our legitimate interest (better understanding the interests of users and improving our services and support).
To send you, in accordance with applicable law, and with your agreement when it so requires, the ANA Newsletter and some marketing, advertising and promotional messages about the products, services or events of ANA and subsidiaries that may interest you. This processing is carried out with your consent and / or for the purpose of our legitimate interest (to transmit you information and relevant contents)
Evaluate the effectiveness of the advertising messages we send and adapt them to our clients and prospects. This processing is based on our legitimate interest (measuring and optimizing the effectiveness of our campaigns) and / or with your consent.
Your data are kept for a duration not exceeding that necessary for the purposes for which they are processed. The tables below mention the retention periods of your data.
Data relating to all users. Data categories & Retention period.
Connection and navigation data, 12 months.
Cookies, 12 months.
Basic information request, 3 years after the closure of the file.
Data relating to your transmission of a content that may be published, 10 years after the reception of the content (beyond this period, these data are archived).
Complaint, claim (including editorial), request for a right of access. 10 years after the closure of the file (beyond this period, these data are archived)
Data issued from questionnaires, opinions or surveys, after the termination of the related marketing study which shall not exceed 3 years (beyond this period, these data are archived).
4.1 What is a cookie?
4.2 Cookies used on the Platform
We use the cookies defined below on this Platform.
• Absolutely necessary cookies (ANA internal cookies) are technical cookies allowing navigation on the Platform and access to its functionalities and Content.
• Functional cookies (ANA internal cookies) make it possible to recognize you when you return to the Platform, to memorize the information relating to your preferences, and thus to improve your browsing quality: adapt the configuration of the Platform to your preferences.
• Audience measurement cookies (Google Analytics third-party cookies): these cookies are used to enable us to recognize and count the number of visitors on the Platform and to collect information on how it is used. (navigation route, most visited pages, etc.).
• Third-party cookies intended to improve the interactivity of the Platform: the Platform relies on certain services offered by third-party websites.
These are posts (Facebook) and tweets (Twitter) posted on the Platform. To learn more about these cookies, we invite you to read the conditions relating to the management of personal data of these websites.
It is also about the possibility of sharing content offered on the Platform with people of your choice by email or via social networks. This sharing feature is implemented by Facebook and Twitter also.
4.3 Refusing and Deleting Cookies
• Configuration of your browser settings
Please note that if you refuse to accept cookies from your internet browser on your device, some features and parts of the Platform may not work properly.
5.1 Cases in which transfers can be made
We keep your data within ANA, except in limited cases defined below.
• Third parties with whom we collaborate may have access to your personal data, in particular the subcontractors we use in relation to some technical, commercial, marketing, legal and e-mail services.
These transfers are always made in the context of the purposes described in Part 2 above, and only data strictly necessary for the achievement of these purposes are concerned.
• We may transfer your data to ANA subsidiaries and / or a third party in case of reorganization of the ANA group (merger, acquisition, split, etc.).
5.2 Places to which transfers can be made
We strive to host and keep your data within the European Union. However, some data may be transferred to countries outside of the European Union, some of which may have a less protective legislation relating to personal data than that applicable within the European Union.
This is the case of data transmitted to some of our subcontractors located outside of the European Union, which we can use for certain specific services.
When such a transfer takes place, we make sure that it is implemented through legal instruments allowing the recipients to comply with all obligations applicable within the European Union as regards data processing (standard contractual clauses of the European Commission), in order to ensure individuals a sufficient level of privacy.
We may send you, in accordance with applicable law, and with your agreement when it so requires, the ANA Newsletter and some marketing, advertising or promotional messages on products, services or events from ANA or its subsidiaries that may interest you.
If you no longer wish to be on our mailing list, you can opt-out by clicking on the unsubscribe link provided in each of our communications or by sending an email to email@example.com
You have the possibility to ask us for a copy of your personal data that we hold, as well as their rectification or erasure. You can also ask us to restrict a processing or to oppose a processing. Note however that in these last two cases, your access to all or part of the Platform and / or to the services may be impacted.
You can request to exercise your right to data portability, that is to say the right to receive the personal data that you have provided us in a structured format, in order to transmit such data to another controller.
You can also make special instructions regarding the fate of your personal data after your death.
In each of the above cases, we are likely, in order to respond to your request, to (i) verify your identity and (ii) ask you to provide us with additional information.
Note that we may retain some information when required by law or when we have a legitimate reason to do so.
If you wish to exercise your rights, you may contact us by e-mail or by post at the addresses indicated below. We will endeavor to respond to your requests within a reasonable time. You also have the possibility to lodge a complaint with a supervisory authority.
DPO Officer: Kyriakos Papadopoulos, firstname.lastname@example.org
160 City Road, EC1V 2NX, London, England, UK.