FIDUCIAIRE DU LYS, a simplified joint-stock company with a capital of €1,000, whose registered office is located at 45, Avenue Montaigne – 75008 Paris, registered with the Paris Trade and Companies Register under number 994 682 623 (“We,” “Our,” “Fiduciaire du Lys“), is the data controller responsible for processing your personal data collected through the Website (as defined below). FIDUCIAIRE DU LYS is committed to protecting and respecting your privacy.

This privacy policy (the “Policy“) sets out the types of personal data we collect and use when you access and visit the Website, as well as how we may use such data.

1.     Definitions

When used with a capital letter, the following terms have the following meanings:

« Content »: refers to all elements comprising the information available on the Website, including but not limited to texts, images, and videos; 

« User »: refers to any internet user accessing or using the Website; 

« Personal Information » : refers, in accordance with Article 4 of Law No. 78-17 of January 6, 1978, to all information that allows, in any form, directly or indirectly, the identification of the natural persons to whom it applies, which may be held by the Website for customer account management, customer relationship management, and for analytical and statistical purposes.

The terms “personal data,” “data subject,” “processor,” and “sensitive data” have the meanings as defined by the General Data Protection Regulation (GDPR: No. 2016-679).

2.    Introduction

This Policy explains who we are, why and how we process personal data collected through your use of the Website, and, if you are the subject of any such personal data, what your rights are and how to contact us if needed.

When you provide us with personal data, we have legal obligations towards you regarding how we use this data. To facilitate reading, we have divided this Policy into several sections:

1. Definitions
2. Introduction
3. What Information May We Collect?
4. How Is Your Personal Information Collected?
5. How and Why Do We Use and Share Your Personal Information?
6. How Long Do We Retain Your Personal Information?
7. Security
8. International Data Transfers
9. Your Rights
10. Contact Details

It is important that you read this Policy along with any other privacy notice or fair processing notice we may provide on the Website at or around the time we collect or process personal data about you (for example, any fair processing notices we may present when you sign up to receive email updates from us) so that you are fully aware of how and why we use your data.

This Policy supplements other notices on our Website and is not intended to override or replace them.

By visiting or otherwise using our Website, you agree to the terms and conditions of use, including any modifications made from time to time, as well as this Policy. If, for any reason, you do not agree with the terms of this Policy, please discontinue use of our Website.

We reserve the right to revise or modify this Policy at any time to reflect changes to our business operations or legal requirements. Where these changes are significant, we will endeavor to inform Users of the Website. However, it is your responsibility to check this Policy before each use of the Website – for reference, the top of this Policy indicates the last update date.

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes during your relationship with Us.

Please note that our Website is not intended for children under the age of 18 (each a “Child” or “Children“), and we do not knowingly collect personal data about Children. If you believe we have collected personal data concerning your Child, you may contact us at contact@fiduciairedulys.com and request that we cease processing such data.

3.    What Information May We Collect?

a.    What Is Personal Data?

When this Policy refers to “personal data,” it means data about you from which you can be identified, such as your name, date of birth, contact details, and even your IP address.
According to the law, all organizations processing your data in France are required to handle it in certain ways and to ensure you receive an appropriate amount of information about how they use it. You also have several rights to request information from these organizations about how they use your data and to prevent them from processing it unlawfully. For more information on these rights, please refer to Section 9 “Your Rights” in this Policy.

b.    What Types of Data Do We Collect from You When You Use the Website?

The personal data we collect from you may include:

• Identity data, including your name, surname, date of birth, and gender;
• Contact data, including your email address, phone number, billing address, and shipping address;
• Device data, including calendar data, location data, and associated time zone information;
• Transaction data, including details of payments you have made and other information or services you have purchased from Us;
• Technical data, including your IP address, login data, browser type and version;
• Profile data, including your username and password, profile picture, interests, preferences, responses, and survey feedback;
• Usage data, including information about how you use the Website;
• Identity verification data, including images of your identification document.

4.    How Is Your Personal Information Collected?

a.    Direct Interactions

When you seek services offered through this Website, contact us via email, request documentation, participate in social media functions, or navigate from one page to another, we may collect, store, and use the personal data you disclose to us.

b.    Automated Technologies or Interactions

We also collect information about you when you visit and interact with the Website using technologies such as cookies. Examples of the information we may collect include:

• Information about your device, browser, or operating system;
• Your IP address;
• Information on the links you click and the pages you visit on our Website;
• The duration of visits to certain pages;
• Topics you have viewed or searched for;
• Page response times;
• Records of download errors and/or broken links;
• Information regarding page interaction (such as scrolling details, clicks, and mouse movements);
• Methods used to exit the page; and
• The complete Uniform Resource Locator (URL) path to, through, and from this Website (including date and time).

We use the above-described data for several different purposes. First, we use it to ensure the Website operates properly and that you can fully benefit from its functionalities. Second, we use the data to monitor online traffic and public engagement with the Website. Third, we use the data to better understand Users’ preferences and interests. We undertake these activities because we have a legitimate interest in doing so.

For more information on this type of technology, please refer to our cookies policy.

c.    Updating Your Information

If you wish to update the information you previously provided to us, you may use the interactive services available or contact us at contact@fiduciairedulys.com

5.    How and Why Do We Use/Share Your Personal Data?

a.    Legal Basis for Processing Your Information

We will only collect and use your personal data under the following conditions :

b.    Sharing Your Personal Data

Depending on how and why you provide us with your personal data, we may share it as follows:

• With selected third parties that we subcontract to provide various services and/or aspects of the Website’s functionality, such as when third-party plugins provide functionalities like discussion forums or image hosting services (see Section e, “Service Providers,” below);

• With analytics and search engine service providers that assist us in improving and optimizing this Website, as described above;

• With fraud enforcement or customs authorities.

We may also disclose your personal data to third parties in the following circumstances:

• If we are required to disclose or share your personal data to comply with a legal obligation, or if we are requested to provide your contact details to a legal authority to assist in a criminal or regulatory investigation; and/or

To enforce or apply the Website’s terms of use, or to protect the rights, property, or safety of our company, customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes.

c.    Service Providers (Data Processors)

Our service providers offer a variety of administrative, statistical, and technical services. We only provide service providers with the minimum amount of personal data necessary to perform the requested services, and we require them to protect this data and not use it for any other purpose. We take these relationships seriously and require all our service providers to sign contracts with us that clearly state their commitment to respecting individual rights and assisting us in supporting you in exercising your rights as a data subject. We do not allow our third-party service providers to use your personal data for their own purposes. Below is a list of our key service providers:

• Web Hosting Provider GANDI, a simplified joint-stock company (SAS) with a capital of 630,000 €, whose registered office is located at 63 Boulevard Massena – 75013 Paris, registered with the Paris Trade and Companies Register under number 423 093 459 (contact: direction@gandi.net / +33 (0) 1 70.37.76.61);
• Developer: AGENCE WEBKAST, a limited liability company (EURL) with a capital of 10,000 €, whose registered office is located at 369 Rue de la Marquerose – 34070 Montpellier, registered with the Montpellier Trade and Companies Register under number 518 725 627 (contact: agence@webkast.fr).

d.    Links to Third-Party Sites

When we provide links to third-party websites, plug-ins, and applications that are not affiliated with this Website, these sites are outside of our control and are not covered by this policy. If you access third-party sites using the provided links, the operators of those sites may collect personal data about you, which may be used in accordance with their own privacy policies. Please review these policies before submitting any personal data to such websites.

e.     Cookies

You may configure your browser to refuse all cookies or certain cookies, or to alert you when websites create or use cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or may not function properly. For more information on the cookies we use, please refer to our Policy.

f.    Change of Purpose

We will use your personal data only for the purposes for which we collected it, unless we reasonably believe that we need to use it for another purpose that is compatible with the original purpose. If you would like an explanation regarding this compatibility, please contact us.
If we need to use your personal data for unrelated purposes, we will inform you and provide you with the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where required or permitted by law.

6.    How long do we retain your personal data?

We will retain your personal data on our systems only for as long as is necessary to provide you with the services you have requested, including to comply with any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in relation to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

By law, we are required to keep basic information about our customers (including contact, identity, financial, and transaction data) for six years after they cease being customers for compliance purposes. In certain circumstances, you can ask us to delete your data: see Section 9 “Your Rights” below for further information, although this may not always be possible if we are required to retain the data for compliance purposes.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We may also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of Users accessing a specific website feature.

7.    Security

FIDUCIAIRE DU LYS takes the protection of your information very seriously. We have implemented appropriate technological and organizational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized manner, altered, or disclosed.

Furthermore, we limit access to your personal data to employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulatory body of a breach when we are legally required to do so.

8.    International Data Transfers

Please note that some of our service providers may be based outside the European Union. These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the processing of your request for information and the provision of services or support services.
When we transfer your data to a service provider located outside the European Union, we seek to ensure that appropriate safeguards are in place to ensure that your personal data is kept secure and that your rights as a data subject are respected. We only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use within the territory of the European Union that give personal data the same protection it has in the European Union.
By submitting your personal information, you agree to this transfer, storage, or processing. If you wish to obtain further information on the mechanism for the transfer of your personal data, please contact our Web Hosting Provider GANDI, at direction@gandi.net / +33 (0) 1 70.37.76.61;

9.    Your Rights

You have the right to lodge a complaint at any time with the Commission Nationale de l’Informatique et des Libertés (CNIL), the French regulatory body responsible for data protection matters (www.cnil.fr).

However, we would appreciate the opportunity to address your concerns before you reach out to the CNIL, so please contact us first.

As a data subject, you have several rights in relation to your personal data. We have described below the various rights you possess, as well as how you can exercise them.

a.    Right of Access

You may, at any time, request access to the personal data that we have about you (you may have heard of this right as a “subject access request”).

Please note that this right allows you to receive a copy of the personal data we have about you to enable you to check that it is correct and to ensure that we are processing it lawfully. It is not a right that allows you to request personal data about other individuals, nor is it a right to request specific documents that do not pertain to your personal data.

You can exercise this right at any time by writing to us, contacting us, and indicating that you are making a subject access request. There is no need to fill out a specific form to make this type of request.

b.    Your Right to Rectification and Erasure

You may, at any time, ask us to correct any personal data we hold about you that you believe is incorrect or inaccurate. You can also ask us to erase personal data if you believe we no longer need to process it, including storing it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data you provide to us, and we may take our own steps to verify that the new data you have provided is accurate. Additionally, we are not always obliged to erase personal data when requested; if, for any reason, we believe we have a good legal reason to continue processing the personal data you request us to erase, we will inform you of this reason when we respond to your request.

You can exercise this right at any time by contacting us and indicating that you are making a request for rectification or erasure of your personal data and on what basis you are making this request. If you want us to replace inaccurate data with new data, you must tell us what the new data is. You do not need to fill out a specific form to make this type of request.

c.    Your Right to Restrict Processing

When we process your personal data on the basis of a legitimate interest (see Sections 4 and 5 of this policy, which explain how and why we use your information), you have the right to ask us to stop processing it in this way if you believe that continuing this processing impacts your fundamental rights and freedoms or if you believe that these legitimate interests are not valid.

You can also ask us to stop processing your personal data (a) if you contest the accuracy of these personal data and wish for us to verify their accuracy; (b) when it has been established that our use of the data is unlawful but you do not want us to erase it; (c) when we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it to enable you to establish, exercise, or defend legal claims.

In certain cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms. We will inform you of this reason, either at the time we first respond to your request or after having had the opportunity to examine and consider it.

You can exercise this right at any time by writing to us at the contact details provided here [To be completed] and indicating that you are making a request for us to stop processing the relevant aspect of your personal data and describing which of the conditions above you believe is relevant to this request. There is no need to fill out a specific form to make this type of request.

d.    Your Right to Data Portability

If you wish to transfer certain personal data that we hold about you and that is processed by automated means to a third party, you can write to us and ask us to provide it to you in a commonly used and machine-readable format. Please note that this right only applies to automated information that you initially consented for us to use or where we used the information to perform a contract with you.

e.    Your Right to Object to Processing

You can object to the processing of your personal data when we rely on a legitimate interest to process that personal data. We will comply with your request unless we have an overriding legitimate interest in the processing or if we need to continue processing your personal data to establish, exercise, or defend a legal claim.

f.    Your Right to Opt-Out of Communications

When we send you commercial communications via email (or other regulated electronic messages), you have the right to opt-out at any time. You can do this by using the “unsubscribe” link that appears in the footer of each communication (or the equivalent mechanism in those communications).

If, for any reason, you cannot use these links, or if you prefer to contact us directly, you can opt-out by writing to us at contact@fiduciairedulys.com and indicating which communications you wish for us to stop sending you.

g.    Your Right to Object to Automated Decision-Making and Profiling

You have the right to be informed of the existence of any automated decision-making and profiling of your personal data, and if applicable, to receive meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing that affects you.

h.    Withdraw Consent, Where This Constitutes the Legal Basis for Processing

You have the right to withdraw your consent at any time when we rely on it to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will inform you if this is the case at the time you withdraw your consent.

i.    Exercising Your Rights

When you write to us to request the exercise of your rights, we have the right to ask you to prove that you are who you claim to be. We may ask you to provide copies of relevant identification documents to help us verify your identity.

To help us process your request, you should clearly indicate the right you wish to exercise and, where applicable, the reasons for exercising it. The clearer and more specific you are, the faster and more efficiently we can process your request. If you do not provide us with sufficient information, we may delay processing your request until you provide additional information (if this is the case, we will inform you).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may also refuse to comply with your request in these circumstances.

We aim to respond to all legitimate requests within one month. It may take us longer than a month if your request is particularly complex or if you have made several requests. In this case, we will notify you and keep you updated.

10. Contact Details

If you have any questions regarding this Policy, if you wish to exercise any of your rights as set out above, or if you believe that the Policy has not been complied with, please contact us by email at contact@fiduciairedulys.com