Privacy Policy

Last update: July 29th, 2023

1 – Definitions

Capitalized terms refer to the following definitions:

The “Company” or “we” or “us” refers to the company EI CEDRIC BONTEMS whose head office is located at 1 square Jean Henri Fabre 30133 Les Angles France, registered under number 91902859700012 whose VAT number is FR95919028597.

The “Site” or the “Website” refers to the internet website(s) accessible from the URL and all subsites allowing to access content areas, membership areas, customer accounts, etc. which are provided by the Company.

A “Processing” corresponds to any operation applied to Data (collection, recording, organization, storage, adaptation, communication by transmission, dissemination, erasure, etc.).

A “Processing Manager” is one who, alone or jointly with others, determines the purposes and means of processing and a “Processor” is one who processes Data on behalf of the Processing Manager. On the Site, unless otherwise stated, we are the Processing Manager.

A “Recipient” is the natural or legal person, public authority, service or any other body which receives communication of personal data, whether or not it is a third party.

“Regulation” means EU Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free circulation of this data (”RGPD”); Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms; the rules applicable to commercial prospecting provided for by the Post and Telecommunications Code, and more generally the laws and regulations applicable to the Data Processing that we carry out.

2 – Direct marketing

The Site presents the activities of the Company and various forms (contact, subscription to our newsletter, etc.).

By completing the forms and communicating with us via the Site, you send us the following categories of information:

In accordance with our legitimate interest, and where applicable when necessary for the execution of pre-contractual measures taken at your request or of a contract, we process the aforementioned Data for the following purposes:

The data used for commercial prospecting management purposes is kept for a maximum of three years from the last active contact from the prospect or customer, and before in the event of withdrawal of your consent to receive messages from us. Data from opinions and contributions are kept for the duration of public access to the opinion on the Site.

In accordance with our legal obligations, identity and contact data will also be processed for the following purposes:

3 – Online Sales

The Site allows you to make purchases, which leads us to process the following Data:
Identity and contact data
Data relating to the contractual and commercial relationship: Details of the content of the order; Pre-contractual exchanges relating to the order (subject, date, etc.); Communications with the Company.
Payment and transactional data: transaction date, amount, means of payment, order number, billing data;
This information is necessary for the management of our customer-prospect file, and more specifically for the following purposes in accordance with our GCS accepted when ordering on the Site and with our legal obligations:
Carry out operations relating to the management of files concerning: contracts including registrations; the orders ; delivery of the product or service; legal and commercial warranties; the bills ; accounting and monitoring of the commercial relationship (after-sales service) including for opinions on the Company’s offers;
Prevention and fight against fraud and means of payment and in particular against bank card fraud;
Management of unpaid bills and litigation, provided that it does not relate to offenses and/or that it does not result in the exclusion of the person from the benefit of a right, a service or a contract.
Secure payment. All transactions made on our Site are secure. Credit card payments are handled by our payment service provider (“PSP”), as indicated in our general terms and conditions or on the order page for our products and services. We thus have an SSL encryption system to protect your personal data as well as the means of payment used. At no time are we directly in possession of your bank details through this process.
Retention periods. The personal data that we process are kept for the durations presented in the table below.
Data concerned Retention period Data processed for commercial prospecting purposes
3 years from the last active behavior of the prospect or the collection of Data
Data necessary for the processing of your order and the management of contractual and commercial relations
3 years from the last active behavior of the customer or, failing that, from the end of the contractual relationship. For accounting documents (purchase orders, delivery slips, customer invoices): 10 years from the end of the financial year
Order contracts for an amount less than 120.00 euros
5 years from the conclusion of the contract.
Order contracts for an amount greater than 120.00 euros
10 years from the date of delivery or service.
Bank details: in case of single payment
13 months for immediate debit payment cards and 15 months for deferred debit payment cards from the date of debit (for the purpose of responding to any dispute)
Bank details: in the event of taking out a subscription with tacit renewal
13 months for immediate debit payment cards and 15 months for deferred debit payment cards from the debit date of the last payment due date, occurring at the end of the subscription (for the purposes of responding to a possible CONTESTATION)

4 – Account Creation

Creating an account is mandatory to place an order on the Site. On the Site, you can create an account and in this case, the following information will be processed:
Identity and contact data
Account connection data: username, password; which may be automatically recorded on the Site only if you consent to this via your browser settings;
Account access and usage data: IP address, connection time, connection duration, account settings, use of any account features.
Processing will be carried out for the purposes of managing authentication procedures, procedures for the loss of identifiers or passwords and for the purposes of executing the order in accordance with the intended purposes for online sales.
The Identity and Contact Data provided when creating the account will be used with your consent to inform you about the Company’s products and services.
The Company may provide tools for creating a profile by adding optional information to your account (identity, social networks, age, profile photo, profession, etc.).

5 – Delivery of physical products

To deliver the products ordered on the Site, we will ask you for your delivery postal address, if this is different from the billing address. If the delivery of a good is intended for a third party, you confirm that you have the authorization to transmit their identity and delivery data. This Data will be transmitted to the carrier responsible for the delivery.
Other information necessary for delivery will be processed in accordance with our GCS and our legitimate interest (delivery method, package size, delivery tracking information, delivery date, receipt note, signature of the note. ..).
The carrier responsible for the delivery applies its own privacy policy to the Data transmitted to it as part of the order or that it collects during the delivery.

6 – Supply of digital content

The legal basis of the Processing aimed at the supply of digital content is contractual and, if not provided for in the T&Cs, responds to our legitimate interest. For this purpose, we will process the following Data:
Identity and contact data
Content access data: Username and password, which can be automatically saved on the Site only if you consent to it via your browser settings and connection information to the access space (IP address, connection time , duration of connection, use of any tools available from this dedicated space, etc.).
Content data: Content consultation and tracking data: Module consultation data, time spent on content; Information about audio files downloaded and/or listened to
Tracking data: Progress indices, statistics and progress tracking; possible grades, surveys and quizzes carried out, past evaluations
Publication data: Content of the publication of your contribution (comment, question, publications, opinions, etc.) date, time, response rate, information on the publication space concerned.
The Site from which the content is accessible may include technical devices that allow the use of the Site to be monitored (logged-in user account, IP address, type of application used, various logs of connection and use of the User account …). The Data from these devices may be used in the context of the fight against counterfeiting, and/or to identify and/or prevent any illicit or non-compliant use of the Site and/or violation of the applicable T&Cs.

7 – Coaching Services

The legal basis of the Processing aimed at providing a personalized support service is contractual and, if not provided for in the GCS, responds to our legitimate interest.
We offer personalized support services in the context of which we will collect and process the following Data:
Organization data: Identity data, contact data, information on slots reserved, canceled, completed, and all the information necessary for the organization of this type of service;
Monitoring data: Progress indices, any notes taken during the support, data from audits, surveys and quizzes carried out, past evaluations, information necessary for the production of a report.
This data can be archived for five years after the end of the support service order contract.

8 – Events

Registrations and organization. We can organize face-to-face or remote events, conferences, festive or business events (the “Events”) which can be free or paid. The personal data necessary for the organisation, management, processing and follow-up of invitations, registrations and participation in these Events are subject to computerized data processing. This Data may be archived for five years after the event.
Picture. In addition, we may be required to fix your image and/or your voice on photo, audio or video media during an Event, in accordance with our T&Cs or any other separate agreement. The recordings may be recorded and published by the Company, including on social networks in accordance with its legitimate interests. If you do not wish to appear, you can turn off your camera in the event of a remote event, stand in the back of the room, not participate in group photos, not wave to the photographer / cameraman, etc. in the event of a face-to-face event.

9 – Social networks and third-party sites

Exchanges on social networks. We can contact you or answer your questions via social networks, if you contacted us in the first place by this means. You are informed that the use of social networks entails the processing of personal data by the providers of these networks (see their privacy policy).
Public information. The information concerning you, which you have transmitted to us, may possibly be enriched for commercial, prospecting, communication, solicitation or marketing purposes, by means of other sources of information such as social networks. This includes information that is said to be “public” or to which we may have access as an administrator of a page or group. The legal basis for this processing is our legitimate interest as a commercial company.
Interconnection. In the event that your member area can connect to another service (for example, a social network) to make cross-mailings, then the third-party service may communicate to us information whose disclosure you have authorized. You are informed that the publishers of third-party services may also collect information concerning the consultation and/or use of the Site, in accordance with their own personal data processing policy. More information on registering for the Site from a third-party account, for:
Facebook :
Google :

10 – Exercise of your rights

For any request to exercise the aforementioned rights or for more information, you can contact the Company at the address: or by post to the address of the Company’s head office indicated at the top.
In accordance with the Regulations, you have the following rights over your Data:
Right of access to your Data, including the right to request a copy, and to the information provided in this privacy policy (Art. 15 GDPR). When the legal basis of the data processing is our legitimate interest, you have the possibility of requesting information relating to the balancing that we have carried out between the interests of our customers and those of the Company prior to this processing.
Right to rectification (Art. 16 GDPR) and updating of your data held by us.
Right to erasure of your Data (Art. 17 GDPR) when the data is no longer necessary for us, you have withdrawn your consent to its Processing (if it was based on our consent) or you object to the Processing based on our legitimate interest or the processing carried out for prospecting purposes or for profiling purposes related to prospecting.
Right to withdraw your consent at any time (Art. 13-2c GDPR) for all data processing based on the legal basis of your consent. In addition, in terms of commercial prospecting, you have the possibility of unsubscribing at any time from our mailing lists by clicking on the unsubscribe link present in our communications or by contacting us to no longer receive any solicitation message.
Right to limit Processing, which, except for compelling reasons, can only be implemented with your consent (Art. 18 GDPR) when:
You dispute the accuracy of the data, for the time necessary to verify them,
If the data processing is unlawful but you oppose the erasure of the data and instead choose the limitation of the processing,
When we no longer need the data but they are still necessary for you to establish, exercise or defend your legal rights.
When you have objected to the processing based on our legitimate interest, for the time necessary to balance our respective interests.
Right to portability of Data directly provided by the data subject when they are subject to automated processing based on your consent or on a contract (Art. 20 GDPR). This right means that you have the option of requesting the communication of this data in a structured, commonly used and machine-readable format so that it can be communicated to another data controller.
Right to object (Art. 21 GDPR) to the processing of your data where such Processing has our legitimate interest as its legal basis.
Right to define the fate of your Data after your death (art. 40-1 of law 78-17 of January 6, 1978) and to possibly choose a trusted third party to whom the Company will have to entrust them.
You can also get more information on the CNIL website.
In the event of a request for exercise, the Company reserves the right to ask you to specify your request and provide proof of identity (which will be kept for one year in the event of exercise of the right of access or rectification and three years in the event of exercise of the right of opposition). If our response does not bring you full satisfaction, you always have the option of lodging a complaint with the personal data protection and control authority to which you report (in France, the CNIL).

11 – Storage periods

Commitments. Means of effective deletion of Data are put in place as soon as the retention or archiving period necessary for the fulfillment of the determined or imposed purposes is reached, in particular after deletion of your account with our Company or at the end of the contract. with our Company.
Minimization. In any case, the Data subject to Processing is not kept beyond the time necessary for the performance of the obligations defined at the conclusion of the contract, or laid down by the legislation in force. Beyond that, they may be anonymized and kept for statistical purposes, in particular in an aggregated form.
Litigation. Similarly, we can archive information demonstrating the performance of our contractual obligations until the expiry of the limitation / foreclosure periods applicable to legal actions, and this for the proper defense of our interests before the courts in the event of litigation. ulterior. This concerns in particular but not exclusively the durations provided for by the Commercial Code, the Civil Code and the Consumer Code.

12 – Recipients

Commitments. We are committed to ensuring that any recipient of data presents sufficient and appropriate contractual guarantees to respect your rights, so that the processing meets the requirements of the GDPR when this regulation applies (in particular with regard to subcontracting). Based on our legal obligations, your Data may be disclosed pursuant to a law, regulation or pursuant to a decision of a competent regulatory or judicial authority.
The information that you communicate to us is for internal use by the authorized persons, it is strictly confidential and cannot be disclosed to third parties, except under the conditions provided for by the Regulations in the event of express agreement or if you have decided to make it public.
Subcontracting. Our external service providers (e.g. suppliers, carriers, etc.) may, in the context of the processing described above, be recipients of personal data when this is necessary for the performance of their mission.
Transfer outside the EU. We undertake to ensure compliance with the applicable regulations relating to the transfer of data to countries located outside the European Union and in particular according to the following methods:
We will transfer visitor, prospect and customer data to countries recognized as offering an adequate level of protection;
When the country of destination does not benefit from an adequate level of protection, we manage the flows using transfer tools that comply with the regulations (standard contractual clauses of the European Commission, in particular).
Aggregation of Non-Personal Data. We may publish, disclose and use aggregate information (information relating to site users, prospects, customers, etc.) that we combine in such a way that no individual person is individually identifiable. This processing is carried out in accordance with our legitimate interest for statistical purposes, sector and market analysis, presentation of our activities, promotional and advertising purposes and other commercial purposes.

13 – IT security

Commitments. We undertake to implement the appropriate technical and organizational measures using physical and logistical security means to limit the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of personal data about you.
Warnings. We invite you to be careful about what you decide to make public on the internet. With regard to personal data, including relating to your private or sensitive life, made public on your initiative or inferred via your contributions, comments and positions of any kind whatsoever on the Site, or even social networks on groups and/or conversations with other users of the Site.
Https protocol. The URL address of the Site is accompanied by a closed padlock or a key appears in your browser indicating the existence of the Https security protocol, applicable to the storage of data in particular. This means that you are in a secure browsing zone, especially when your credit card number is requested.
Data Breach. In the event that an event resulting in the realization of the risks of modification, disappearance or unauthorized access to the Data, we undertake to:
Examine the causes of the incident;
Take the necessary measures to limit the negative effects and damages that may result from said incident;
Notify the incident to the competent authority and/or the persons concerned as soon as possible when this meets a legal requirement.
Under no circumstances can the commitments defined in the point above be assimilated to any acknowledgment of fault or liability for the occurrence of this incident.

14 – General

Mandatory or optional character. On the Site, you are informed of the mandatory nature of the answers by the presence of an asterisk or any other type of mention. In the event of an incomplete request (for example: online registration or order, request for information, etc.), the Company reserves the right to request additional information or to rule out by any technical means the possibility of validating the form concerned.
Hypertext links. The Site may provide links to other sites, applications and services than its own, which may be operated by third-party companies. We are not responsible for the processing of personal data carried out by these third-party sites, or sites pointing to the Site, the user of which is invited to consult the personal data protection policies for more information. The Policy is applicable only to the activities of the Company, which cannot be held responsible for any breaches by a third party of its obligations with regard to the protection of personal data.
Scope. The Policy is not exhaustive of all processing and we reserve the right to supplement it by any means.
Language. The Policy is written in French. In the event that it is translated into one or more languages, only the French text shall prevail in the event of a dispute.
Non-Waiver. The temporary or permanent non-application of one or more clauses hereof does not constitute a waiver on its part of the other clauses hereof which continue to produce their effects.
Changes – Updates. We reserve the right to modify this privacy policy. The persons concerned will be notified when this is provided for by the applicable regulations. The date of update is indicated in the header and we invite you to consult it regularly.

Information about cookies

Presentation: Cookies and tracers (hereinafter “cookies”) refer to connection cookies and more generally, any file – deposited during the consultation of a website or a mobile application, the installation or the use of software in the user’s terminal equipment – having as its object the reading or writing of information in this equipment. Cookies allow us to collect Site consultation data (IP address, Internet service provider, hardware configuration, software configuration, browser type and language, etc.).
Cookies may be placed by the Company or by third-party companies without your consent when they are strictly necessary for the operation of the site or to facilitate communication to the public online, for example when they are intended for authentication, to keep store the contents of a shopping cart, to generate traffic statistics, or to limit free access to a sample of content requested by users.
Duration: The maximum retention period for cookies is 13 months after their first deposit in your terminal and this duration is not extended with each visit.
Consent to the deposit of cookies: You are informed of the presence of cookies that are not strictly necessary by an information banner on the Site. With the exception of cases of use not subject to consent, cookies and tracers will only be stored on your terminal with your express consent. You may be periodically asked to reiterate your consent, to ensure that it is still valid.
Cookie settings: You always have the possibility to modify your preferences directly via the Site thanks to the dedicated settings tool accessible by clicking here or via your browser settings (Firefox with enhanced protection against tracking; Firefox with deletion of cookies ; Chrome ; Safari ; Opera ; Microsoft Edge). You can also configure your terminal’s browser to activate the “Do Not Track” option, which will indicate to the sites visited, advertising agencies or applications that you do not wish to be “tracked”. This feature is available for the following browsers, among others: Firefox; Chromium; Safari; Opera; Microsoft Edge.
In the event of refusal of cookies not essential to the operation of the Site: Certain functionalities of the Site such as video players or interactive content use services offered by third parties and deposit cookies allowing them to identify your consultation of the content. If you refuse to deposit these cookies, the personalization features will not be able to work and the content that will be offered to you (in particular video suggestions or advertisements) will still be present but will be unrelated to your areas of interest.