Privacy Policy

On 01/09/2021

SUPERHUMAIN undertakes to process and protect your personal data in accordance with the provisions of the General Data Protection Regulation (GDPR) and the French Data Protection Act (Loi Informatique et Libertés) so you can browse our website www.superhumain.org (hereinafter referred to as the “Site”) with full peace of mind.

SUPERHUMAIN attaches great importance to your privacy and ensures the protection, confidentiality, integrity, availability, and security of the personal data you entrust to us through all our communication channels and services hosted on the Site.

This Privacy Policy informs you about how we collect and process your personal data. SUPERHUMAIN recommends that you read it carefully. This translation is provided for information purposes only and shall neither modify nor override the French version of the present Privacy Policy. In the event of a conflict between the translation of this Privacy Policy and the original French version of same, the original French version of this Privacy Policy shall always prevail.

1. Definitions

- Personal Data: any information relating to an identified or identifiable natural person in accordance with Article 4 of the GDPR (hereinafter referred to as “Data”).

- User / Users: any natural person(s) logging on to www.superhumain.org.

- Data Controller: the person who determines the purposes and means of the processing of personal data.

2. Data controller

The Controller of the User’s Data, in accordance with the GDPR, is:

SUPERHUMAIN

Simplified joint-stock companywith a share capital of € 5000 euros

Registered in the Lyon Trade and Companies Register under the number 902 299 866

Registered office: Wojo Business Centre - 4, place Amédée bonnet – 69002 Lyon Cedex

E-mail: info[@]superhumain. org

Telephone number: (33) 6 76 06 48 29

3. Legal basins and purposes of data processing

We collect and process the User’s Data within the scope of our Site and to offer Users the best possible service.

3.1 Visiting the site

Users can visit our Site without providing any personal information.

When visiting our Site for information purposes only, we do not process the User’s Data except for that transmitted by the User’s browser in order for the User to visit our Site, as well as the information transmitted with express consent by the User within the framework of the set and accepted cookie management policy.

In the context of a simple visit to the Site, SUPERHUMAIN processes the User’s Data in order to provide the User with technical access to our Site on the basis of the execution of a contract, or the execution of pre-contractual measures, to inform the User about our services and/or in pursuance of our legitimate interests so that we can ensure the technical provision of the Site. Our legitimate interest is to provide Users with an attractive, technically functional and user-friendly Site, to take all measures necessary to protect our Site from cybersecurity risks, and to prevent third parties from being exposed to such risks on our Site.

For more information, please refer to Article 9 below.

In any event, the thus-collected Data is kept for thirteen months from the date of insertion of the corresponding cookie.

3.2 Customer Area

A customer area is accessible from the Site, specific to each User via an email address and a password provided at the time of registration.

In the context of the use of the aforementioned personal area, SUPERHUMAIN processes the User’s Data for the User to easily access his or her personal area and to offer the services requested by the User on the basis of the execution of a contract concluded when subscribing to one or several training modules, or the execution of pre-contractual measures taken at the User’s request.

The User’s Data is kept for the period strictly necessary for the proper management of the User’s personal area, and in any event for a period not exceeding three years from the last request to which the User failed to respond and, in the absence of a request for deletion and/or opposition from the User in the meantime.

We shall not pass on the User’s Data to any third party without the User’s express consent, except as per stated in section 5 below.

3.3 Contact Form

If the User contacts us through our contact form available on our Site, the User must enter his or her surname, first name, e-mail address, occupation, and subject of the message prior to sending us same. The User’s telephone number is optional.

The User’s Data is stored for the purpose of processing the User’s request and/or in case the User has any questions for us.
In the context of the contact form, SUPERHUMAIN processes the User’s Data for the purpose of responding to the User’s requests on the basis of the pursuit of our legitimate interest, which is to provide the User with appropriate responses to his or her requests.

All the thus-provided data shall be stored on our servers.

The User’s Data is kept for the period strictly necessary for the proper management of our commercial relationship, and in any event for a period not exceeding three years from the last request to which the User did not respond and, in the absence of a request for deletion and/or opposition from the User in the meantime.

If the User has given his or her consent, this data may be reused by SUPERHUMAIN in the framework of communications via our newsletter or for further commercial operations.

We shall not pass on the User’s Data to any third party without the User’s express consent, except as per stated in section 5 below.

3.4 Newsletter

SUPERHUMAIN offers the possibility for the User to subscribe to a newsletter in the relevant section by entering his or her email address. We shall then regularly send our newsletter to the User, including news about our services and related subjects.

In the context of our newsletter, we process the User’s Data to send the User our newsletter on the legal basis of consent, from which the User can withdraw at any time.

The User shall have the right to withdraw his or her consent to receive this newsletter at any time by clicking on the “unsubscribe” link provided at the end of each newsletter received by email, or by contacting us at info[@]superhumain.org.

The User’s Data is kept for the time strictly necessary to send the aforementioned newsletter, and in any event for a period not exceeding three years from the date of registration or since the last request to which the User did not respond and, in the absence of a request for deletion and/or opposition from the User in the meantime. We shall not pass on the User’s Data to any third party without the User’s express consent, except as per stated in section 5 below.

We shall not pass on the User’s Data to any third party without the User’s express consent, except as per stated in section 5 below.

4. Deletion

The User’s Data is deleted as soon as the purpose of its processing has ceased, or no longer exists, or upon request for its deletion by the User.

The User’s Data is also deleted after the above-mentioned retention periods have expired, unless it is necessary or legitimate to retain the User’s Data for the execution or termination of a contract, or if the User has given his or her express consent to its retention.

5. Data recipients

The collected User’s Data are intended for the Data Controller and any authorized person within SUPERHUMAIN. The latter are bound to respect the confidentiality of the Data provided, and are regularly trained in Data protection and security.

Nevertheless, SUPERHUMAIN may communicate the User’s Data to other recipients providing services related to the Site and its services, to the extent authorized or provided for by law. In this case, we shall limit the transfer of the User’s Data to what is strictly necessary.

Our service providers receive the User’s Data as subcontractors and are strictly bound by our instructions regarding the processing of the User’s Data, including compliance with data protection regulations. In addition, the recipients process the User’s Data provided by us in an independent and responsible manner.

Finally, the User’s Data may be transmitted to any authorities and/or jurisdictions.

SUPERHUMAIN lists the categories of recipients who may receive its Users’ Data below:

- Payment: In the context of the fight against online payment fraud and/or debt recovery, we may pass the User’s financial information to an external service provider equipped with an online fraud detection tool in order to authenticate a payment or recover a debt.

- Disclosure: We may also disclose the Data provided by the User on our Site to third parties who provide services related to the Site.

- Legal: We may also disclose the Data provided to us by the User in the event that such disclosure is necessary to comply with applicable law, respond to a subpoena, or exercise or defend a legal right.

6. Cookies

The User’s consent is formalized when he or she accepts the cookie banner on the home page. The period of retention of the consent thus obtained is thirteen months from the insertion of the corresponding cookie.

6.1 What is a cookie?

A cookie is a small text file that records information on the hard drive of the User’s terminal (computer, tablet, mobile) about his or her browsing on a website (date and time of loading pages; browser used and language; pages viewed, frequency and duration of visits to the site, number of visits, sources of the visit, location).

Each time the User returns to the same website, his or her browser retrieves and returns the relevant cookie(s) to the website’s server.

6.2 Purpose of Cookies

Whenever the User visits the Site, SUPERHUMAIN and/or third-party partners using the services (technical or advertising partners) may install various cookies on the User’s terminal (computer, tablet, mobile) in order to send content and services relevant to the User’s interests.

Cookies pose no risk to the User’s terminal, for they carry no no viruses or malware.

6.3 Types of Cookies

The cookies we use are stored on the User’s terminal for a maximum period of two years from the date they are initially deposited or, in the event they are updated later, from the said date.

SUPERHUMAIN uses the following types of cookies:

- Technical cookies :

These cookies are strictly necessary for the proper functioning of the Site, for browsing the Site and for using the requested basic functions (language cookies, identification cookies, etc.).
In the event that these cookies are blocked by browser configuration, SUPERHUMAIN shall no longer ensure the proper and optimal functioning of the Site.

- Functional and performance cookies (Analytics):

These cookies improve the User’s experience on the Site. For example, they enable the User’s preferences on the Site to be memorized; they also make it possible to measure the audience and to establish statistics and volumes of frequentation and use of the various elements composing the Site.

- Advertising cookies:

These cookies may be used for advertising purposes (such as Google Ad Manager, Smart, etc.) and help to make the ads seen by the User more relevant to him or her.

- Social media cookies:

These cookies, or plugins, allow the User to share content related to the Site on social media, or to share information related to the User’s browsing or his or her interests concerning the Site on social media.

Social media cookies are used within the scope of the “share” button on the Site and originating from social media platforms such as Facebook, Instagram, Twitter, and LinkedIn. If the User has an account on any or all of aforementioned social media platforms, and if he or she clicks on one of said buttons, the relevant social media platform will make the link between the User’s profile and his or her visit to the Site.

Furthermore, SUPERHUMAIN invites all Users to consult the personal data protection of the aforementioned social media platforms in order to be aware of the processing purposes their data and of their rights regarding said processing.

Names of the cookies used on the Site:

  • Technical Cookies (always enabled)

Technical cookies are necessary for the proper functioning of the www.superhumain.org website or are intended to enable and/or facilitate your browsing experience. These cookies are law compliant and safe. Session cookies only remain valid while you visit our website, and are deleted from your device when you quit your Internet browser. Persistent cookies remain on your device and are reused during subsequent visits. Their deletion may affect Site browsing and access. They do not require your prior consent.

  • Analytics Cookies

Analytics cookies (e.g. Google Analytics, Criteo, etc.) provide us with anonymous statistics on the use of the Site in order to detect navigation problems and to optimise its ergonomics, navigation and content. Deactivating these cookies will prevent us from analysing traffic on www.superhumain.org.

  • Social Media Cookies

Social media cookies allow you to share content from our website with others, and/or to share your views and opinions about the content of our website on social media platforms such as Facebook, Instagram, Twitter and LinkedIn. These cookies may take the form of “share” or “like” buttons when provided by the social media platform itself, thus likely to identify you through the said button even if you did not use it while visiting our website.

  • Advertising Cookies

Advertising cookies allow SUPERHUMAIN and its partners to display personalized advertising in the advertising sections of our website according to your navigation and profile. The use of these sections helps fund the contents and services provided by SUPERHUMAIN to its Users free of charge. Advertisements may be geolocated according to your location.

6.4 Cookie Settings

Users can block the use of cookies or receive a notification before a new cookie is set by updating the settings in their Internet browser.

Users can consult the “Help” section on the menu bar of most Internet browsers to prevent the browser from accepting new cookies, to request notification about new cookies from the browser, and to disable all cookies. Please note, disabling cookies may block access to certain features of the Site.

Users can also manage their cookie preferences on some of the most popular web browsers by following the links below:

• Google Chrome

Follow the instructions on this link: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647 or proceed as follows:

1. Click on “More” then “Settings” on the top right section of your browser window;
2. Under “Privacy and Security”, click on “Cookies and other site data”;
3. Select the relevant options.

• Mozilla Firefox

Follow the instructions on this link: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences or proceed as follows:

1. Click on “Menu” then “Options” on the top right section of your browser window;
2. Click on “Privacy and Security”;
3. Under “Cookies and site data”, click on “Manage data”;
4. Select the relevant options.

• Internet Explorer

Follow the instructions on this link: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies or proceed as follows:

1. Select the “Tools” menu and then “Internet Options” in your browser;
2. Click on “Privacy”, and “Advanced” under “Settings”;
3. Select the relevant options.

• Apple Safari

Follow the instructions on this link: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac or proceed as follows:

1. Select the “Edit” menu, then “Preferences” in your browser;
2. Cliquer sur l’option « Données personnelles »
3. Click on “Cookies”;
4. Select the relevant options.

• Opéra
Follow the instructions on this link: https://help.opera.com/en/latest/web-preferences/#cookies or proceed as follows:

1. Select the “Settings” menu in your browser;
2. Click on “Advanced” in the left sidebar, then on “Privacy and Security”;
3. Click on “Site Settings“;
4. Click on “Cookies and site data”;
5. Select the relevant options.

Vous pouvez également modifier le paramétrage de vos cookies via le lien présent sur le bandeau cookie qui apparaît sur le Site.

For more information, please refer to the “update parameters” guide in the tab “Vos traces” on the CNIL website (https://www.cnil.fr/vos-droits/vos-traces/les-cookies/conseils-aux-internautes/).

7. Data transfer

The Data collected is transferred to a data centre located in the United States.

As part of this transfer, SUPERHUMAIN has signed a contractual agreement with ACTIVCAMPAIGN, located at 1 North Dearborn St - 5th Floor, Chicago, IL 60602, UNITED STATES, which contains contractual provisions that have been validated by the European Commission and EU legislation in order to ensure that the User’s Data is properly protected when transferred to such locations outside the European Union.

The aforementioned Standard Contractual Clauses are available via the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

8. Data security

SUPERHUMAIN implements security and confidentiality measures to protect the Data provided by the User against unauthorized access and use.

To this end, appropriate technical and organisational measures are taken to prevent the loss, misuse, alteration, and/or deletion of the User’s personal data. These measures are adapted according to the level of sensitivity of the data processed, and to the level of risk involved in the processing or its implementation.

However, Users should be aware that despite all security measures, no transmission of Data over the Internet is 100% secure and that any information communicated online can potentially be intercepted and used by persons other than the intended recipient.

9. Rights of the persons concerned

In the context of the collection and processing of their Data, Users have the following rights:

• Right to Information: Users have the right to clear, transparent and easily understandable information about how we use their Data. That is why we provide Users with this information in this Privacy Policy.

• Right of Access: Users have the right, at any time, to request confirmation as to whether or not their Data is being processed and, in the event that it is being processed, they are entitled to receive a copy of the information about their Data and certain other information (including processing purposes, Data categories, recipient categories, the intended retention period, the origin of the Data, the use of automated decision-making and, in the event of Data transfer to a non-member State, the appropriate safeguards).

We may, however, refuse to provide Users with Data should doing so require us to disclose Data about another person or prejudice the rights of that other person.

• Right to Rectification: Users have the right to request the rectification or updating of any incomplete, inaccurate, or erroneous Data.

• Right to Erasure (also known as the “right to be forgotten”): Users have the right, under certain conditions, to request the erasure or deletion, as soon as possible, of their Data whenever we have no compelling reason to carry on using it, or whenever its use is unlawful.

However, the right to erasure does not apply, in particular, whenever the processing of the Data is required (i) to exercise the right to freedom of opinion and information, (ii) to comply with a legal obligation to which we are subject (e.g. legal retention obligations) or (iii) to assert, exercise or defend legal claims.

• Right to Limit Processing: Users have the right, under certain conditions, to block or limit any further use of their Data. In the event of limitation, we may still keep the User’s Data without using it.

• Right to Data Portability: Users have the right to receive, in a structured, common and machine-readable format, any Personal Data they have made available to us.

• Right to Object: Users have the right to object to the processing of their Data, under certain conditions, and in view of their personal circumstances. In such an event, we shall cease processing the User’s Data unless said processing must be continued for legal reasons, for the exercise or defence of our rights in connection with any legal/judicial claims, or if we are able to demonstrate that there are “compelling legitimate grounds for the processing which override the User’s interests and rights and freedoms”.

• Right to Revoke Consent: Users have the right to revoke their declaration of consent to Data protection at any time. The revocation of consent does not affect the lawfulness of the processing carried out pursuant to that consent until it is revoked.

Users can exercise these rights by sending a request to the Data Protection Officer at info[@]superhumain.org.

Prior to responding to such a request, we may verify the User’s identity and/or ask the User to provide additional information.

Finally, we shall respond to the User’s request within a reasonable time, and in any event within the time limits set by law. Should the User deem our response unsatisfactory, he or she may lodge a complaint with the National Commission on Information Technology and Civil Liberties (CNIL).

In the event that the User exercises one or more rights, we are required to inform all recipients to whom the User’s Personal Data has been disclosed, with the User’s prior express consent, unless this is impossible or would require disproportionate effort. Users have the right to obtain information about said recipients.

10. Droit d’introduire une réclamation auprès d’une autorité de contrôle

Without prejudice to any other administrative or legal remedy, Users have the right to appeal to the CNIL.

The CNIL shall inform the claimant about the progress and outcome of his or her complaint, including the possibility of legal recourse in accordance with Article 78 of the GDPR.

However, we recommend that Users always send complaints to us at info[@]superhumain.org; we shall reply within two months.

11. Updates to the policy

By using the Site, Users consent to the collection, use and disclosure of their Data as described in this Policy. This Policy reflects the current business practices of SUPERHUMAIN and may be updated at any time.

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