Privacy Policy

1. General information

The entities responsible for processing your personal data are:

ICAM STRASBOURG-EUROPE
An association under local law, with its head office at 2 rue de Madrid in Schiltigheim (67300). SIREN 517 733 374 – APE 8542Z

We have therefore established guidelines, and take responsibility for the processing and protection of your personal data.

Through our Platform, you may be asked to provide Icam, site de Strasbourg-Europe with personal data, when creating a customer account, ordering products or subscribing to the newsletter for example.

Icam, site de Strasbourg-Europe may also collect certain information relating to your browsing on the Website, as described in more detail in the “Cookies” section below.

You have a permanent right to oppose, access, rectify and delete all the data collected pertaining to you. To exercise this right, you can contact our data protection officer:

Our DPO is Mr José PONTON: dpo@ecam-strasbourg.eu

2. Data concerned

The data we collect and use varies depending on the products, services or functionalities you wish to use. The personal data that we collect, or that you choose to provide to us, includes in particular:

• identification data, such as your first name, last name, company name, telephone numbers, email address that you provide when you visit the Website or decide to commit to a project by signing a contract or quotation;
• electronic identification data available on or from your computer (such as “cookies” or “IP addresses”). Your electronic identification data makes it possible to identify or geolocate your connection terminal (without being more specific than the city), or the pages consulted on the Website during your navigation, and is generally insufficient on its own to identify you in a nominative way. For more information on the browsing information collected, please consult Article 5 concerning cookies and connection cookies.

3. Your rights

In accordance with the regulations in force, you have various rights concerning your personal data. These rights can be exercised directly and at any time by contacting us at the following address: dpo@ecam-strasbourg.eu or Icam, site de Strasbourg-Europe, 2 rue de Madrid in Schiltigheim (67300) – France, simply by indicating the reason for your request and the right you wish to exercise. If there is any doubt regarding your identity, we may ask you for a copy of your identity card or other proof of identity. Your rights are as follows:

• The right of access: The right to request a copy of the personal data we hold about you. If your request is unjustified or unreasonable, we may charge you a fee for this request.
• The right of rectification: The right to request the correction of erroneous personal data that we have on you. We would like to remind you that if you have a customer account, you can access the section corresponding to your personal data in order to modify or update them. You must ensure that this information is true and accurate. Similarly, you undertake to inform us of any changes or modifications to this data. We also remind you that, in principle, you should only provide your own personal data and not that of a third party. Any damage or loss caused by providing inaccurate or incomplete information in our data collection forms is the sole responsibility of the user of our Platform.
• The right to deletion: The right to request the deletion of your data, when one of the following conditions is met:
  • your personal data is no longer necessary for the purposes for which it was collected,
  • you have withdrawn your consent, and there are no other legal grounds to continue processing your personal data,
  • you have exercised your right to object in a valid manner,
  • the processing of your data is not lawful,
  • or your personal data must be deleted to comply with a legal obligation.

However, there are cases where you cannot exercise your right to deletion, even if one of these conditions is fulfilled (namely when the processing of your data is necessary for freedom of expression and information, to comply with a legal obligation, to contest/exercise/defend a legal right or for statistical archiving purposes in the public interest, or scientific or historical research).

To delete your customer account, simply send your request to dpo@ecam-strasbourg.eu or to Icam, site de Strasbourg-Europe, 2 rue de Madrid in Schiltigheim (67300) – France.

• The right to object: The right to object on grounds relating to your particular situation to the processing of your personal data based on our legitimate interest. In this case, we will stop processing your data, unless we have a legitimate reason to continue processing your data. If your data is used for marketing purposes, you have the right to object without having to justify your reasons.
• The right to restrict processing: The right to request, in certain cases, the temporary suspension of the processing of some of your data or their conservation, if needed, for longer than necessary.
• The right to portability: If the processing of your personal data is based on your consent or the performance of the contract and if the processing is carried out by automated means, you will have the right to request the receipt of your data in a structured, commonly used, and machine-readable format so that it can be transferred to another entity, provided that this is technically possible.
• The right to set out instructions on what to do with your personal data in the event of your death.

You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State where you normally reside, work or where the breach is alleged to have occurred, if you consider that the processing of your personal data constitutes a breach of the applicable regulations. In France, the supervisory authority is the following: the French National Commission for Information Technology and Civil Liberties: CNIL, 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, Tel: +33 (0)1 53 73 22 22

You also have the right to withdraw your consent, at any time, for any processing based on consent. To cancel your subscription to our newsletter, simply click on the unsubscribe link in each e-mail.

4. Management of personal data by ICAM STRASBOURG-EUROPE

4.1 Purposes and legal grounds of data collection

The following summary allows you to understand what Icam, site de Strasbourg-Europe uses your personal data for (the “purpose”) and the legal basis (the “legal grounds”):

To carry out commercial prospecting and marketing activities:
If you decide to subscribe to the newsletter, you consent to us processing your data in order to manage your subscription and/or to send you information related to our products and/or services as well as commercial prospecting messages through various means, such as e-mail or SMS. If you participate in a competition via the Platform or our social networks, you consent to your data being used in connection with the competition and the awarding of the prizes you have won. Unless you give your express consent, the data collected are not used for advertising purposes by us or our business partners. If you agree in advance to the applicable legal terms and conditions (including the social networks you use), we may post photographs you have shared publicly or with us on our Platform or our various social networks. Provided we have your prior consent, we may record data relating to your preferences (such as your height or colourimetry ) to personalize your experience with Icam, site de Strasbourg-Europe.

Legitimate interest:
We have a legitimate interest in contacting you by telephone or post to inform you of our offers, provided you did not object to this when your data was collected (please note that you can object at any time by sending an e-mail to dpo@ecam-strasbourg.eu). Similarly, unless you object, we have a legitimate interest in sending you commercial messages by electronic means (e.g. SMS or e-mail) if you are already a customer and if these messages only concern products or services similar to those we have already provided to you.

Respond to your questions, requests or complaints transferred via the available channels
If your request is related to a contact by email or telephone, processing is necessary for the proper management of our services.

Legal obligations
If your question concerns the exercise of the rights set out in Article 3 “Your rights” or relates to a complaint about our products or services, we will need to process your data to comply with our legal obligations.

To produce anonymous statistics on site traffic
We believe that we have a legitimate interest in analysing the usability and quality of our Platform in order to improve the experience of our users and provide a better quality Platform for our customers. Please read Article 5 “Cookies and login cookies” for more information.

Conducting customer satisfaction surveys or studies
We consider that we have a legitimate interest in conducting surveys and polls to analyse customer satisfaction in order to improve the quality of our products and services

4.2 Duration of data retention

Management of our customer and prospect files
Retention for a period of 3 years from your last contact with us (that is when a customer purchases something, or when a prospect clicks on a hyperlink in an e-mail) or until you withdraw your consent.

Your questions sent via the contact form
Retention for the time needed to process your request.

Your electronic identification data (your login cookies collected, subject to your consent and the settings of your terminal, using cookies and other tracers placed on our Website)
Kept in accordance with the applicable regulations for a period not exceeding 13 months. For more details on cookies, how they work and how you can disable them, see section 5 “Cookies and login cookies” below.

Secondly, regardless of the retention period needed to fulfil the purpose of the data processing, it may be justified for us to archive your data for a limited period of time, in a secure manner and with restricted access, for various reasons:

• To comply with a legal obligation to retain data (for example, the retention of personal data for accounting purposes is 10 years).
• To protect against possible liability claims arising from the processing of your personal data. In order to manage pre-litigation and litigation, we may archive your data for evidentiary purposes for the period during which we may be held liable (duration of the related statute of limitations: civil, commercial, etc.).

Once the retention period imposed by law has elapsed and any actions have lapsed, your personal data will be deleted or anonymised.

4.3 Recipients of the data

Your personal data is intended for use by the services of Icam, site de Strasbourg-Europe concerned by your requests. However:

• The processing of your personal data is authorised to third parties that we use to provide certain services. These include:
  • technical, logistic, transport and delivery service providers,
  • payment service providers and fraud detection and prevention entities.
  • Only when you have given us your consent may we share your data with certain business partners.

In any case, there is no transfer outside France, and Icam, site de Strasbourg-Europe will not transmit your personal data, except:

• if Icam, site de Strasbourg-Europe needs to share this information with third parties to provide the service you request, or
• if Icam, site de Strasbourg-Europe is required by a judicial or other administrative authority to disclose the information, or
• if you have given your prior consent to the sharing of such information.

In this case, transferring your personal data outside of France will be done with appropriate safeguards and will preserve the security of your data.

Icam, site de Strasbourg-Europe may transfer your personal data to judicial and police authorities, regulatory authorities, public bodies or third party companies in order to comply with a court order, subpoena, summons, search warrant or any other legal or regulatory obligation or request. Such transfers may also be made for the purposes of fraud protection or the investigation of possible crime.

4.4 Data security

Icam, site de Strasbourg-Europe has taken all reasonable precautions to ensure the confidentiality, integrity and availability of processed personal data and to prevent them from being distorted, damaged, destroyed or accessed by unauthorised parties. Technical and organisational security measures have been implemented for this purpose.

Icam, site de Strasbourg-Europe does not however control all the risks associated with the workings of the Internet and draws the attention of Internet users to the existence of possible risks inherent in its use and operation.

For the purposes of technical storage of your personal data, your data will be centralised at Icam, site de Strasbourg-Europe:

• 2 rue de Madrid à Schiltigheim (67300)

Icam, site de Strasbourg-Europe attaches the utmost importance to the protection and security of its information systems. Tools have been put in place to enable Icam, site de Strasbourg-Europe to detect possible security breaches. These tools may incidentally lead to security teams having access to personal data. This data will be collected and processed exclusively for the purpose of managing these flaws and in compliance with the applicable regulations on the protection of personal data.

5. Cookies and login cookies

5.1 What is a cookie?

A cookie is a text file that may be stored in a dedicated space on the hard drive of your electronic equipment when you consult an online service using your browser. A cookie file allows its issuer to identify the terminal in which it is stored, for the duration of the validity or storage of the cookie.

5.2 Cookies issued on the Website

When you connect to the Website, Icam, site de Strasbourg-Europe may, subject to your choices, install various cookies that allow it to recognise the browser you are using during the period of validity of the cookie concerned.

The cookies are issued for the following purposes:

• to establish statistics and volumes of traffic and use of the various elements making up the Website (sections and content visited, routes taken), enabling Icam, site de Strasbourg-Europe to improve the interest and ergonomics of the services, as well as the visibility of the content published;
• to enable or facilitate your browsing on the Website, or to provide you with the online communication services that you request during your browsing, and thus :
  • to adapt the presentation of the Website to the display preferences of your terminal (language used, display resolution, operating system used, etc.) during your visits to the Website, according to your terminal’s viewing or reading hardware and software;
  • to memorise information relating to a form that you have filled in on the Website (registration or access to your account) or to products, services or information that you have chosen on the Website (contents of an order basket etc.);
  • to share information with advertisers on other websites in order to offer you relevant advertisements in line with your interests. In this respect, we use advertising cookies.

5.3 Cookies issued on the Site by third parties

Icam, site de Strasbourg-Europe may include third party computer applications on the Website, which allow you to share the contents of the Website with other persons or to inform these other persons of your consultation or your opinion concerning a content of the Website.

The issue and use of cookies by third parties are subject to the privacy protection policies of these third parties.

Icam, site de Strasbourg-Europe does not control the process used by social networks to collect information relating to your browsing on the Site. Icam, site de Strasbourg-Europe invites you to consult the privacy protection policies of these social networks in order to learn about the purposes of use, namely advertising, of the browsing information they may collect through these application buttons. These protection policies should enable you to exercise your choices with regard to these social networks, in particular by configuring your user accounts for each of these networks.

The Website may contain cookies issued by third parties (communication agencies, audience measurement companies, etc.) that enable the latter, during the period of validity of these cookies, to collect browsing information relating to the Terminals consulting the Website, in particular in order to measure the effectiveness of paid referencing campaigns with search engines.

5.4 Your choices regarding cookies

There are several options available to you for managing cookies. Any settings you make may affect your browsing experience and your access to certain services that require the use of cookies.

You can choose at any time to express and modify your wishes regarding cookies, by the means described below.

You can configure your browser software so that cookies are stored in your terminal or, on the contrary, that they are rejected, either systematically or according to their source.

You can also configure your browser software so that you are offered the option of accepting or refusing cookies on an ad hoc basis, before a cookie is likely to be stored in your terminal. For more information, see “How to express your choices, depending on the browser you are using”

To modify your choices concerning cookies, consult the “Cookie settings” section at the bottom of the Website page.

(a) The Cookie Agreement

The recording of a cookie in a terminal is essentially subject to the will of the terminal user, which s/he can express and modify free of charge at any time through the choices offered by his/her browser software.

If you have accepted in your browser software the recording of cookies in your terminal, the cookies integrated in the pages and contents that you have consulted may be stored temporarily in a dedicated space in your terminal. They will only be readable there by their issuer.

(b) Refusing cookies

If you do not want cookies to be stored on your terminal, or if you delete the cookies stored on your terminal, you will no longer be able to benefit from a certain number of functions which are nevertheless necessary to navigate in certain areas of the Website.

This would be the case if you attempted to access content or services that require you to identify yourself. This would also be the case if Icam, site de Strasbourg-Europe or its service providers were unable to recognise, for technical compatibility purposes, the type of browser used by your terminal, its language and display settings or the country from which your terminal appears to be connected to the Internet.

Where applicable, Icam, site de Strasbourg-Europe declines all responsibility for the consequences related to the degraded functioning of its services resulting from our inability to record or consult the cookies necessary for their functioning, and which you may have refused or deleted.

(c) How to exercise your choices, depending on the browser you are using

Each browser has a different configuration when it comes to managing cookies and your choices. It is described in the help menu of your browser, which will allow you to know how to modify your wishes regarding cookies.

5.5 If you share your terminal with other people

If your terminal is used by several people, and when the same terminal has several browsers, Icam, site de Strasbourg-Europe cannot be certain that the services and advertisements intended for your terminal correspond to your own use of this terminal, and not that of another user of this terminal.

Where applicable, sharing your terminal with other people, and the configuration of your browser’s settings with regard to cookies, is a matter of your free choice and your own responsibility.

For more information on cookies and their use, you can consult the file of the French National Commission for Information Technology and Civil Liberties (CNIL) at the following address: https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs.

6. Changes to the Charter

Icam, site de Strasbourg-Europe may have to modify the Charter, and will ensure that you are informed of this either by a special mention on the website, or by a personalised warning, particularly in the context of the sending of newsletters.

7. Personal policies relating to minors

The Website is not intended for minors. However, access to the Website is not forbidden to them, as it does not contain any content forbidden to minors under the age of 18.

If information regarding a minor is collected by the Website, the minor’s legal representative will be able to contact dpo@ecam-strasbourg.eu to rectify, modify or delete this information.