Privacy Policy

Last updated on 12/26/2022

As of: December 15, 2022

I. Personal Data Protection Policy

APSHAN, a simplified joint stock company with a capital of 1,500 euros, registered in the Paris Trade and Companies Register under number 910 956 689, and whose registered office is located at 6, rue d'Armaillé - 75017 PARIS (the " Company " or " APSHAN ") collects, records and processes the personal data that you provide as a user of the website that it publishes, which can be accessed at www.apshan.com (hereinafter " the Site " or " the Website ").

In the context of this processing, the Company complies with the provisions of Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (hereinafter referred to as the " RGPD "), as well as with Law No. 78-17 of January 6, 1978, as amended, relating to information technology, files and freedoms.

All the terms reproduced and used in this data protection policy (hereinafter " the Privacy Policy ") are also defined in the General Conditions of Use Internal Site, applicable to Providers, and the General Conditions of Sale, applicable to Customers, both of which are accessible on the Website. Data " means " personal data " as defined in the aforementioned texts.

1. Person in charge of the processing of personal data

The Company is responsible for processing personal data, as defined in Article 4 of the GDPR.

For any questions or to exercise one of the rights listed in Article 7 below, you can send your requests to : Mr. In Soo Seguier, either by mail at 6, rue d'Armaillé - 75017 PARIS, or by e-mail at hello@apshan.com.

The provision of your personal data is based on the contractual relationship established between the Company and you, through the signing of one or more contracts or through your use of the Site. You are informed that if you do not provide this information, you will not be able to benefit from the Service offered online by the Company on the Website, as the Company may not be able to verify your identity.

The Company informs you that it keeps an activity register of the processing of personal data that it carries out.

The Company guarantees to have taken all necessary measures to ensure the security of the data processing which is hosted in Europe with the exception of the third parties mentioned in article 3.

2. Purpose of the Processing of Personal Data

The Company collects, stores and processes your personal data as a result of your adherence to the General Terms and Conditions of Sale, General Terms and Conditions of Use or the Partnership Agreement that you have signed with the Company.

The purposes of the processing are as follows:

- Ensure the management and the follow-up of the users of the Website;

- Website management;

- Newsletter sending;

- Commercial prospecting and marketing purposes.

The categories of persons concerned by the processing of personal data are Customers and Providers who have created an account on the Website.

The categories of personal data processed are the following:

- Full name;

- Date and place of birth;

- Email address;

- IP address;

- Personal Account ID / Login / Password;

- Mailing address;

- Phone number.

3. Recipients, Subcontractors and Disclosure of Data to Third Parties

The Company informs you of the following subcontractors in connection with the processing of your data:

- Host : 02SWITCH - SAS with a capital of 100 000 €, registered at the R.C.S. of Clermont-Ferrand under the number 510 909 807, domiciled Chemin des Pardiaux - 63000 Clermont-Ferrand - 0033 444 446 040

Apart from the companies listed above, the Company does not transfer the personal data it collects, stores and processes.

Any change in the present list will be brought to your attention and you will have the possibility of objecting to it either by post to the address 6, rue d'Armaillé - 75017 PARIS, or by e-mail to the address hello@apshan.com.

4. Protective Measures

Any individual who has access to the Company's data processing is committed to keeping it confidential. Access to the data processing is personal and controlled by access codes. The Company's premises are locked.

On your side, you must identify yourself by means of a personal account, nominative and personalized, by the insertion of a login and a personal and confidential password.

This authentication system guarantees traceability and access to personal data under conditions of security and confidentiality in accordance with the provisions of the regulations in force and the applicable recommendations of the CNIL.

You personally undertake to take all useful measures to ensure the complete confidentiality of your login and password and not to communicate, transfer or make available to a third party these passwords and login.

5. Transfer outside the EU

The Company does not transfer any personal data that it processes to third parties located outside the European Union, with the exception of the third parties mentioned in Article 3. In case of change, the Company will inform you and you will have the possibility to oppose it either by mail at 6, rue d'Armaillé - 75017 PARIS, or by e-mail at hello@apshan.com.

6. Duration of the retention of Personal Data

The data collected by the Company is kept for the duration of your registration on the Website and for 2 years after its end.

You are also informed that the Company may keep this data beyond the above-mentioned period if it appears necessary for it to establish proof of a finding, the exercise or defence of its legal rights, for the protection of the rights of another natural or legal person or for important reasons of public interest of the Union or of a Member State.

7. Rights of the Persons Concerned by the Processing of Personal Data

Right of access: You have a right of access to the data collected, stored and processed by the Company concerning you, subject to respect for the rights and freedoms of third parties.

Right of rectification and limitation: You have the right to request the rectification of data processed by the Company that are inaccurate. If necessary, the Company will have the right to ask you for proof.

Right to erasure - right to be forgotten: You have the possibility to ask the Company to delete your collected data (i) when they are no longer necessary for the processing in view of its purposes, (ii) when you exercise your right to object and there is no compelling legitimate reason for the Company to keep them, or (iii) when the data has been processed unlawfully or if the data must be deleted by virtue of a legal obligation. You are informed, however, that the Company may retain such data in the event of the establishment, exercise or defense of its legal rights or for legitimate reasons.

Right to limit processing: You have the possibility to implement your right to limitation of processing, under the conditions of the GDPR.

Right to Data Portability: You have the option of requesting from the Company that your data processed by it be transmitted to you in a structured, readable and commonly used electronic format. You also have the option of requesting that the Company transmit your data in the same format to another data controller, where technically possible. The Company may object to the exercise of this right if the portability infringes the rights and freedoms of a third party.

Right of opposition: You have the possibility to object to the processing of your data by the Company for prospecting purposes. To exercise this right, you can make a request either by post to the address 6, rue d'Armaillé - 75017 PARIS, or by e-mail to the address hello@apshan.com.

8. Responsible Controlling Authority

For any complaint, you can contact the National Commission for Information Technology and Liberties (CNIL).

II. Cookie Policy

1. Definitions

Cookies are pieces of information that are deposited on your terminal equipment by the Site's server. They are used by the Site to send information to your browser and allow it to send information back to the Site (for example, a session identifier or language choice).

Only the sender of a cookie can read or modify the information contained in it.

You are informed that, during your visits to the Site, cookies may be installed on your terminal equipment.

2. Consent

When you first visit the Site, you will be asked to accept or refuse the use of certain cookies.

If you do not want cookies to be installed or read on your terminal equipment, an "opt-out" cookie will be placed on your equipment so that the Company can record the information that you have objected to the use of cookies. If you delete this refusal cookie, it will no longer be possible to identify you as having refused the use of cookies.

Also, when you accept the use of cookies, a consent cookie is set.

The consent or refusal cookies must remain on your terminal equipment. You can modify your wishes at any time as indicated in article 5 entitled " Cookie management ".

In the context of the use of cookies as described in this document, the Company will be likely to process personal data concerning you, as the controller, under the conditions of I of the present document.

3. Purpose of the Cookies Used

Some of the cookies used by the Company have the sole purpose of enabling or facilitating electronic communication (detection of connection errors, identification of connection points, etc.).

Others are strictly necessary for the provision of online communication services at your express request (e.g., screen display preferences).

Others are used for the purpose of :

- To analyze the frequentation and the use which is made of the Site, to be able to make it evolve in the direction of an improvement of the experiment of navigation;

- To make the Site more user-friendly and interactive.

4. Cookies Used on the Website

The cookies used on the Site are :

- The Company's cookies;

- Third-party cookies selected by the Company for specific purposes.

The cookies deposited by the tools of the Site are detailed in the table below:

- Cookies related to the saving of choices in terms of cookie consent: retention period 13 months ;

- Cookies related to the user's session ID: lifetime equal to the session duration;

- Technical cookies: their purpose is to facilitate your navigation on the Site and to allow us to offer you the Site's functionalities and services; lifespan: 1 year.

The companies that deposit cookies are the following:

- Google Tag Manager

- WeGlot : Translation of the site

- Facebook pixel : Ads tracking 

- Hotjar : Heatmap

- Axeptio: Cookie Manager

- Matomo tag : Analytics

- LinkedIn insight Tag: Ads tracking

- Sendinblue : Email marketing

- Tally Script : Form tracking creation

5. Your Cookie Management

You have several options for deleting and managing cookies and other trackers.

=> Browser settings

If most browsers are set by default to accept the installation of cookies, you have the possibility, if you wish, to choose to accept all cookies, to reject them systematically or to choose which ones you accept according to their sender. You can also regularly delete cookies from your terminal via your browser.

However, don't forget to configure all the browsers on your various terminals (tablets, smartphones, computers, etc.).

Each browser has a different configuration for 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.

However, the Company draws your attention to the fact that by setting your browser to refuse cookies, certain functionalities, pages and areas of the Site will not be accessible, for which the Company cannot be held responsible.

=> Opposition Platforms

Many advertising industry platforms also offer you the ability to decline or accept cookies used by their member companies. These centralized mechanisms do not block the display of advertisements, but only prevent the installation of cookies that allow ads to be tailored to your interests.