Privacy policy

This privacy policy (“Policy”) describes how personally identifiable information (“Personal Information”) you may provide on clemenceaugroup.com (“Website” or “Service”) and any of its related products and services (collectively, “Services”) is collected, protected and used.

It also describes the choices you have regarding the use of your personal information and how you can access and update this information. This policy constitutes a legally binding agreement between you (“User”, “you” or “your”) and the operator of this website (“Operator”, “we”, “us” or “our”).

By accessing and using the Website and Services, you acknowledge that you have read, understood and agree to be bound by the terms of this Agreement. This policy does not apply to the practices of companies we do not own or control, or to people we do not employ or manage.

Automatic information gathering

Our top priority is the security of our customers’ data, which is why we apply a “no logs” policy. We may only process minimal user data to the extent absolutely necessary to maintain the website and services.

The information collected automatically is used solely to identify potential cases of abuse and to compile statistical information concerning the use and traffic of the website and services. This statistical information is not otherwise aggregated to identify any particular user of the system.

Collection of personal information

You may access and use the Web Site and Services without telling us who you are or revealing any information that could identify you as a specific, identifiable individual. However, if you wish to use certain functions of the website, you may be asked to provide certain personal information (for example, your name and e-mail address). We receive and store any information you knowingly provide to us when you fill out online forms on the website. Where necessary, this information may include the following:

– Details such as name, country of residence, etc.
– Contact information such as e-mail address, address, etc.

Some of the information we collect comes directly from you via the website and services. However, we may also collect personal information about you from other sources, such as public databases and our joint marketing partners. You may choose not to provide us with your personal information, but then you may not be able to take advantage of certain features of the website. Users who do not know which information is mandatory are invited to contact us.

Use and processing of collected information

In order to make the website and services available to you, or to comply with a legal obligation, we need to collect and use certain personal information. If you do not provide the information we request, we may not be able to provide you with the products or services you have requested. Any information we collect from you may be used for the following purposes:
– respond to inquiries and offer assistance
– manage and operate the website and services.

The processing of your personal information depends on how you interact with the website and services, where you are in the world and whether any of the following apply: (i) you have given your consent for one or more specific purposes; however, this does not apply where the processing of Personal Information is subject to the California Consumer Privacy Protection Act or the European Data Protection Act; (ii) the provision of information is necessary for the performance of an agreement with you and/or any pre-contractual obligations thereof; (iii) processing is necessary to comply with a legal obligation to which you are subject; (iv) processing is connected with a task carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Please note that under certain legislation, we may be allowed to process information until you object to such processing (by unsubscribing), without having to invoke consent or any of the other legal bases below. In all cases, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a legal or contractual requirement, or a requirement necessary to enter into a contract.

Disclosure of information

Depending on the services requested, or if it is necessary to complete a transaction or provide a service you have requested, we may share your information, with your consent, with trusted third parties who work with us, as well as with any affiliates or subsidiaries we rely on to help us operate the website and the services offered to you. We do not share personal information with unaffiliated third parties. These service providers are not authorized to use or disclose your information except as necessary to provide services on our behalf or to comply with legal requirements. We may share your personal information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies regarding personal information. These third parties receive the personal information they need only to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes.

Information retention

We will retain and use your personal information for as long as necessary to comply with our legal obligations, resolve disputes and enforce our agreements, unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your Personal Information after you have updated or deleted it, but not in a way that would identify you personally. Once the retention period has expired, personal information will be deleted. Consequently, the right of access, the right of erasure, the right of rectification and the right to data portability cannot be applied after the expiry of the retention period.

Information transfer

Depending on your location, data transfers may involve the transfer and storage of your information in a country other than your own. You have the right to inquire about the legal basis for transfers of information to a country outside the European Union or to any international organization governed by public international law or created by two or more countries, such as the UN, as well as the security measures taken by us to protect your information. If such a transfer takes place, you can find out more by consulting the relevant sections of this policy or by contacting us using the information provided in the contact section.

User rights

You may exercise certain rights with regard to the information we process. In particular, you have the right to do the following: (i) you have the right to withdraw your consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to know whether information is being processed by us, to obtain information about certain aspects of the processing and to obtain a copy of the information being processed; (iv) you have the right to verify the accuracy of your information and to request that it be updated or corrected; (v) you have the right, in certain circumstances, to restrict the processing of your information, in which case we will not process your information for any purpose other than storage; (vi) you have the right, in certain circumstances, to obtain from us the deletion of your personal information; (vii) you have the right to receive your information in a structured, commonly used and machine-readable format and, if technically possible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract to which you are party or on the latter’s pre-contractual obligations.

The right to object to processing

Where Personal Information is processed in the public interest, in the exercise of official authority vested in us or for the purposes of our legitimate interests, you may object to such processing by providing a reason related to your particular situation to justify the objection.

Data protection rights under the GDPR

If you are a resident of the European Economic Area (EEA), you have certain data protection rights and the Operator aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Information. If you would like to be informed of the personal information we hold about you and would like it removed from our systems, please contact us. Under certain circumstances, you have the following data protection rights: -You have the right to request access to your Personal Information that we store and have the ability to access your Personal Information. -You have the right to ask us to correct any personal information that you believe to be inaccurate. You also have the right to ask us to complete any personal information that you consider incomplete. -You have the right to request the deletion of your personal information under certain conditions of this policy. -You have the right to object to our processing of your personal data. -You have the right to request restrictions on the processing of your personal information. When you restrict the processing of your personal information, we may retain it but will no longer process it. You have the right to receive a copy of the information we hold about you in a structured, machine-readable and commonly used format. -You also have the right to withdraw your consent at any time where the operator has relied on your consent to process your personal information. -You have the right to complain to a data protection authority about our collection and use of your personal information. For further information, please contact your local data protection authority in the European Economic Area (EEA).

Privacy rights in California

In addition to the rights explained in this policy, California residents who provide personal information (as defined in the law) to obtain products or services for personal, family or household purposes have the right to request and obtain from us, once per calendar year, information about the personal information we have shared, if any, with other companies for marketing purposes. Where applicable, this information will include the categories of personal information as well as the names and addresses of the companies with which we have shared this personal information for the previous calendar year (for example, requests made during the current year will receive information about the previous year). To obtain this information, please contact us.

How to exercise these rights

Any request to exercise your rights may be addressed to the Operator using the contact details provided in this document. Please note that we may ask you to verify your identity before responding to these requests. Your request must provide sufficient information to allow us to verify that you are the person you claim to be or that you are the authorized representative of that person. You must include sufficient details to enable us to properly understand and respond to your request. We cannot respond to your request or provide you with personal information if we have not first verified your identity or authority to make such a request and confirmed that the personal information is about you.

Children's privacy

We do not knowingly collect personal information from children under the age of 18. If you are under the age of 18, please do not submit any personal information through the website and services. We encourage parents and legal guardians to monitor their children’s use of the Internet and to help enforce this policy by instructing their children never to provide personal information through the Website and Services without their permission. If you have reason to believe that a child under the age of 18 has provided us with personal information through the Website and Services, please contact us. You must also be at least 16 years old to consent to the processing of your personal information in your country (in some countries, we may authorize your parent or guardian to do so on your behalf).

Do not follow" signals

Some browsers integrate a “Do not track” function that signals to the websites you visit that you do not wish your online activity to be tracked. Tracking is not the same as using or collecting information about a website. For these purposes, tracking refers to the collection of personally identifiable information from consumers who use or visit a website or online service as they move between different websites over time. The website and services do not track their visitors over time and on third-party websites. However, some third-party sites may keep track of your browsing activities when they offer you content, enabling them to personalize what they present to you.

Information security

We secure the information you provide on computer servers in a controlled and secure environment, protected against unauthorized access, use or disclosure. We maintain reasonable administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of personal information under our control and custody. However, no data transmission over the Internet or wireless networks can be guaranteed. Therefore, while we strive to protect your personal information, you acknowledge that (i) there are security and privacy limitations on the Internet that are beyond our control; (ii) the security, integrity and confidentiality of all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) this information and data may be accessed or modified in transit by a third party, despite our best efforts.

Data breach

If we learn that the security of the Website and Services has been compromised or that users’ personal information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate action, including, but not limited to, investigation and reporting, and notifying and cooperating with law enforcement authorities. In the event of a data breach, we will use reasonable efforts to notify data subjects if we believe there is a reasonable risk of harm to the user as a result of the breach or if notification is otherwise required by law. In this case, we will send you an e-mail.

Changes and modifications

We reserve the right to change this policy or its terms relating to the website and services from time to time, at our discretion, and will notify you of any material changes in the way we treat personal information. When we do, we’ll send you an e-mail to let you know. We may also inform you by other means, at our discretion, for example via the contact details you have provided. Any updated version of this Policy will be effective immediately upon publication of the revised Policy, unless otherwise specified. Your continued use of the website and services after the effective date of the revised policy (or such other action as may be specified at that time) will constitute your consent to such changes. However, we will not, without your consent, use your personal information in a manner materially different from that stated at the time of collection of your personal information.

Acceptance of this policy

You acknowledge that you have read this policy and agree to all of its terms and conditions. By accessing and using the Website and Services, you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and the Services.

Contact us

If you would like to contact us to better understand this Policy or if you would like to contact us regarding any issues relating to individual rights and your Personal Information, you can send an e-mail to .