1. PURPOSE

When pre-registering for the Newz priority waiting list, Newz, whose contact details are detailed in Article 11 below (“Newz”), is required to collect personal data about the Holder (the “Personal Data”).

This policy (hereinafter the “Policy”) complements the General Terms and Conditions of Use of the pre-registration phase on the waiting list of Newz (the “GTC”) and must be read in conjunction with these GTC.

The purpose of the Policy is to inform Registrants who pre-register on the waiting list of the use made by Newz of their Personal Data, in compliance with the applicable regulations.

The Policy may be modified at any time by Newz, in order to comply with any legislative, regulatory, jurisprudential, editorial or technical changes. The version of the Policy applicable is the one accessible online when pre-registering with Newz. In any case, the Holder’s pre-registration to Newz implies the unconditional applicability of the latest version of the Policy.

2. DEFINITIONS

– Newz” means all or part of the services and features set forth in Section 3 below, related to such service offered by Newz and subscribed by a Registrant to Newz;

– “Username” means the email address of which the Registrant is the exclusive user, and the confidential password that is specific to the Registrant and sufficiently complex.

– For the purposes of the Policy, the terms “Processor(s)”, “Processor” and “Subcontractor” shall have the definitions assigned to them by Article 4 of the GDPR.

– “Personal Data” means any information referred to in Article 4.1 of the GDPR relating to a Data Controller and detailed in Article 4 of the Policy.

– “Recipients” means any person entitled to receive communication of Personal Data and designated in Article 5 of the Policy,

– “Applicable Regulations” means together the Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms (the “Data Protection Act”) and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the Processing of personal data and on the free movement of such Personal Data, and repealing Directive 95/46/EC (the “GDPR”).

– “Third Party” means any person other than the Holder, Newz or Newz’s service providers,

– “Registrant” means any natural person of legal age or any natural person under the age of fifteen years or having the authorization of a legal representative, who has pre-registered with Newz. A Holder is required to pre-register with Newz under the conditions set forth in these Terms of Use. In the event that the Registrant is a minor, his/her legal representative(s) shall remain responsible for the Registrant’s compliance with the GTC.

– User”: any person visiting this site without being identified as a Newz pre-registrant.

3. PURPOSE, LEGAL BASIS AND DATA CONTROLLER

3.1 Processing of Personal Data for the purpose of pre-registration to Newz

Personal Data are processed by Newz for the purpose of pre-registration on a waiting list and for the purpose of providing information to the Holder when accessing his pre-registration or by e-mail (unless he objects in accordance with Article 6 below) on the evolution of the features and services it includes. In this context, the legal basis for the Processing of Personal Data is the agreement given by the Holder to Newz when he/she pre-registers.

For these purposes only, the Data Controller is Newz, a company in the process of being formed.

4. PERSONAL DATA COLLECTED ?

In order to allow the pre-registration to Newz, it is necessary for Newz to collect Personal Data, notably

– The Holder’s first name, if he/she so wishes

– The e-mail address identifying the Member.

– The Holder’s authentication cookie, as detailed in Article 9 below.

This data is only processed for the purpose of re-registration to Newz, based on the execution of the General Terms of Use.

In addition, the Registrant may be invited to provide Newz with additional Personal Data, on a free and optional basis, if he/she so wishes, allowing him/her to express his/her preferences on the type of content he/she wishes to consult or on the products and services he/she is more particularly interested in. Where applicable, Newz’s Processing of such optional Personal Data is based on the legal basis of Newz’s legitimate interest (Article 6.1.f of the GDPR), accompanied by Personal Data protection measures.

5. RECIPIENTS OF PERSONAL DATA

The Personal Data is intended for (i) Newz, (ii) authorized personnel of Newz who, by virtue of their duties, need to know it for the purposes of the Processing, (iii) Newz’s service providers, (v) and, where applicable, authorized public bodies in order to meet the legal obligations incumbent on Newz, as well as judicial and ministerial officers in the context of administrative, judicial or mediation proceedings related to Newz’s activities.

6. THE RIGHTS OF THE HOLDER

Subject to an express request and proof of identity to Newz, the Registrant has a right to access, rectify and object to its Personal Data, as well as a right to erasure, under the conditions of the Applicable Regulation, by contacting Newz at the postal or e-mail address mentioned in Article 10 of the Policy.

In case of exercise of the right to object, Newz will cease the Processing of the Personal Data subject to the said objection, except in case of legitimate and compelling reason(s) for the Processing concerned, or to ensure the establishment, exercise or defense of its legal rights, in accordance with the Applicable Regulation. Where applicable, Newz will inform the Data Controller of the reasons why the rights it exercises cannot be satisfied in whole or in part.

Subject to an express request and proof of identity to Newz, the Registrant also has the right to obtain a copy of the Personal Data he/she has provided to Newz when pre-registering to Newz. If necessary, this Personal Data will be transmitted to him/her on an electronic medium, in a structured, commonly used and machine-readable format, in particular in order to allow the Holder to transmit them to another Data Controller.

The Holder has the right to provide Newz at any time with instructions concerning the fate of his Personal Data after his death.

7. RETENTION PERIODS FOR PERSONAL DATA

In accordance with Applicable Regulations, the Registrant’s Personal Data is kept for the duration strictly necessary for the purposes pursued as set forth in this Policy, and for the performance of the TOU.

In particular:

– Personal Data collected for the purpose of pre-registering for Newz are kept for a maximum of 2 years from the last consultation of the Newz pre-registration site.

– The Personal Data collected to manage the requests of opposition to the treatment are preserved for a maximum duration of 2 years as from the taking into account of the right of opposition ;

– The Personal Data Processed to manage requests for access and rectification of Personal Data are kept for a maximum of 2 years from the receipt of the requests ;

In the event of a claim or complaint by the Holder or a Third Party, the Personal Data associated with the Holder’s Newz may have to be kept for the purposes of managing the claim or for the duration of the resulting litigation, until the exhaustion of all means of appeal and enforcement.

8. SECURITY

In accordance with the Applicable Regulations, Newz implements technical and organizational measures to ensure the security and confidentiality of the Personal Data collected and Processed, and in particular to prevent them from being distorted, damaged or communicated to unauthorized Third Parties, by ensuring a level of security appropriate to the risks associated with the Processing and the nature of the Personal Data to be protected, taking into account the level of technology and the cost of implementation.

Newz may include links to external websites or sources, in particular to the websites and/or applications of its partners. This Policy does not apply to the Processing of Personal Data carried out by Third Parties, including on external sites or sources accessed by the Holder through Newz. Consequently, Newz shall not be responsible for the practices of these external sites or sources, including its possible partners, in terms of Processing of personal data, which are governed, where applicable, by the personal data protection policies specific to the latter.

It is reminded that the Holder contributes to the protection of his Personal Data by respecting the rules of confidentiality prescribed in the GCU, particularly concerning his Identifiers.

9. COOKIES AND OTHER TECHNICAL IDENTIFIERS

9.1 Purpose of use of cookies and other technical identifiers ?

Among the Personal Data, Newz may Process Personal Data resulting from the deposit or reading of cookies or other technical identifiers of the device (computer, smartphone, tablet, etc.) and/or the browser software allowing the Registrant to browse the Internet (“Terminal”)

The Processing by Newz of a technical identifier of the Terminal used by the Cardholder is necessary to associate this identifier with Newz of the latter and to allow him/her to use it for the purposes referred to in the GCU and in this Policy. The Processing of this identifier makes it possible to determine the performance and relevance for the Cardholder of the sponsorships that he/she would carry out. In particular, it allows the detection of malfunctions, authentication failures at Newz and the analysis of aggregate statistics on the frequency and types of use.

The information associated with these technical identifiers concerns in particular the pages visited, the type of navigation software or Terminal used, the IP address.

Thus, if the Holder configures his Terminal or his navigation software in such a way as to prevent Newz from reading a cookie or a technical identifier or to modify it in such a way as to prevent the Terminal concerned from being associated with the Holder’s pre-registration information, News will not be able to inform the Holder of his progress in obtaining a free subscription.

9.2 Duration of validity of cookies

In accordance with the Applicable Regulations and the recommendations of the Commission Nationale Informatique et Libertés (“CNIL”), the validity period of the cookies that may be deposited on the Holder’s Terminal is 13 (thirteen) months.

10. CONTACT AND COMPLAINTS

For any request or in the event of a dispute between Newz and the User concerning the Processing of his/her Personal Data, the latter may address his/her request or complaint to Newz by contacting it at the following e-mail address: dpo[at]newz.press.

Newz will endeavor to find a satisfactory solution to ensure compliance with the Applicable Regulation.

In the absence of a response from Newz or if the dispute persists despite Newz’s proposal, the Registrant may file a complaint with the CNIL or the supervisory authority of the European Union Member State in which the Registrant is ordinarily resident.