This personal data protection policy (hereinafter the “Policy”) sets out how Buffet Crampon processes personal data collected in connection with the use of the Clarimate application (hereinafter the “Application”).
1. APPLICABLE LEGISLATION
The Policy is made pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter “General Data Protection Regulation” or “GDPR”) and French Law no. 78-17 of 6 January 1978 (hereinafter “Loi Informatique et Libertés”).
2. DATA CONTROLLER
The data controller is Buffet Crampon, a French société par actions simplifiée, having its registered office at 5 rue Maurice Bertheaux, 78711 Mantes-la-Ville, France, registered with the Versailles trade and companies register under no. n°750 220 980, hereinafter “Buffet Crampon”.
3. CONTACT
Buffet Crampon
5 rue Maurice Bertheaux,
78711 Mantes-la-Ville, France
Email: rgpd@buffetcrampon.com
4. DATA SUBJECT
The data subjects of the personal data processing carried out by Buffet Crampon, under the conditions defined in the Policy, are the persons using the Application. They are at least 15 years old and over.
5. PROCESSING ACTIVITIES
| Purpose of the processing | Types of data processed | Legal bases for the processing | Retention period |
|---|---|---|---|
| Account creation and login to the Application Processing mandatory to use the Application except where provided otherwise. | Login details (email address and password) Information on user (user name (first and last names), country, user type (teacher, student, artist, dealer or other), school, age range) | Performance of the contract with the user | For as long as the account remains active or for 12 consecutive months following the user's last login |
| Provision of the services through the Application Processing mandatory to use the Application. | Training sets data (user name, file directory that the file was stored in, computer information (OS, build number), persistent data (volume settings, midi settings), instrument type (mark, model, barrel length) | Performance of the contract with the user | For as long as the account remains active or for 12 consecutive months following the user's last login |
| Improvement of the Application Processing mandatory to use the Application. | Application usage data (button presses, opened pages, unique users, established from a generated key from the app’s first launch, returning users, established from the generated key, selected dropdown values, dialog boxes spawned, screen resolution/window resolution, device error report, reed calibration values, instrument type) (mark and model), connection method and failures, occasional battery monitoring, periodic recognition quality of notes) Crash report data | Legitimate interest of Buffet Crampon to process data to improve the Application and ensure better service quality | 13 months after collection |
| Marketing Processing optional to use the Application. | Email address Personal information (first and last name, country, user type (teacher, student, artist, dealer, or other), school, age range) | Legitimate interest of Buffet Crampon to send marketing emails related to its products and services | Duration of the user’s active account plus 3 years or 3 years from the last contact with the user |
6. RECIPIENTS OF THE DATA
Personal data may be accessible to some data processors (IT and hosting providers).
Personal data are not disclosed to any other third parties.
Buffet Crampon may use processors to carry out the processing activities, in accordance
with article 60 of the Loi Informatique et Libertés and article 28 of GDPR.
7. TRANSFER OUTSIDE EUROPEAN UNION
Data may be transferred outside European Union based on adequacy decisions within the meaning of article 45 of the GDPR or subject to appropriate safeguards within the meaning of article 46 of the GDPR, such as standard contractual clauses adopted by the European Commission.
8. RETENTION PERIOD
Data are retained for the periods specified in article 5 according to the processing activities carried out.
Some data may be retained for an additional period necessary to comply with Buffet Crampon’s legal or regulatory obligations or for the exercise of Buffet Crampon’s rights in legal proceedings.
Beyond these periods, certain anonymized data may be retained for archiving or statistical purposes.
9. DATA SUBJECTS’ RIGHTS
Each data subject has the right to access, rectify, erase, restrict, object to the processing of their data, data portability, withdrawal of consent, and to set directives regarding the fate of their data after death, under the conditions and limits provided by GDPR and the Loi Informatique et Libertés.
Data subjects may exercise their rights at any time by contacting Buffet Crampon using the contact details provided in article 3 .
Some personal data can be directly modified by the user through the Application. This may limit the relevance of certain rights, such as rectification or access, where data has been changed or deleted by the user.
In order to ensure confidentiality and protection of personal data, Buffet Crampon may require the data subject to identify themselves before responding to their request. For this purpose, the data subject will be asked to attach a copy of a valid official identity document, such as an identity card or passport, to support their request.
All requests will be processed promptly and in accordance with the applicable law. In some cases, personal data can only be deleted after a certain period imposed by applicable regulations and prescription rules. In such cases, Buffet Crampon will retain the data until the permitted deletion date.
The data subject is informed that in the event of refusal to provide personal data or exercise of their right to deletion or objection, Buffet Crampon may have to suspend or terminate all or part of the services provided to the data subject through the Application.
In case of a dispute regarding the use of their data, the data subject has the right to lodge a complaint with the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés - CNIL) or any competent data protection authority.
10. OBJECTION TO RECEIVING COMMERCIAL COMMUNICATIONS
Any recipient of communications related to the promotion of Buffet Crampon’s activities may unsubscribe at any time, even if they have previously expressed a different preference, by clicking on the unsubscribe link included in such communications, by changing their settings in the Application or by sending a request to the contact details above.
UPDATES
Buffet Crampon may periodically update the Policy.
The data subject will be informed of any changes by any means, including, but not limited to,
by email or notification on the Application.