Data Protection Policy / Website Privacy Policy

SAN FERNANDO is committed to preserving the confidentiality of the information provided online and, in general, to protecting the personal information and privacy of its employees, partners, providers, website visitors, and anyone using its services in general, in compliance with the current regulations and particularly the law known as “Data Processing and Liberties” No. 78-17 of January 6, 1978, as amended, and the European Regulation 2016/679 (GDPR) concerning the protection of personal data.

The purpose of this policy is to inform you about:

• The objectives pursued by data processing (purposes);
• The types of personal data we collect about you;
• How your personal data are processed;
• The conditions and modalities of using your personal data and your rights in this regard, in compliance with European and French legislation.

All operations on your personal data are carried out in compliance with the current regulations, especially Regulation No. 2016/679, known as the General Data Protection Regulation (“GDPR”), Law No. 78-17 of January 6, 1978, relating to data processing, files, and freedoms, and any national legislation applicable to data protection.

Without prejudice to the choices offered to you by this document and by the Law, you acknowledge having read and accepted this Policy.

If you disagree with the terms of this policy, you are free not to provide personal data. However, you are warned that the communication of some of these data conditions the access to services and that, in the absence of such communication, some functionalities and services may be degraded.

1. DEFINITIONS
   The following terms will have the following meaning:

A “Personal Data” refers to any information related to an identified or identifiable natural person, directly or indirectly, by reference to an identification number or one or more elements specific to them.

A “Processing of personal data” any operation or set of operations performed or not using automated processes and applied to data, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, alignment or combination, limitation, erasure or destruction.

The “Data Controller” is the natural or legal person who determines the purposes and means of processing, i.e., the objective and how to achieve it. In practice and generally, it is the private or public entity represented by its legal representative.

A “Processor” refers to the natural or legal person, or any other body, which processes personal data on behalf of the data controller.

The “Authorized Third Parties” the natural or legal person, public authority, service or body, under the direct authority of the data controller or processor, authorized to process the personal data.

2. DATA CONTROLLER AND DATA PROTECTION OFFICER
   The data controller for the site https://san-fernando.ec/ is:

EXCELLENCE

The legal representative is François de Bretagne, President.

SAN FERNANDO has appointed a data protection officer reachable at the following address: j.roudet@salpa.fr

3. COLLECTED PERSONAL DATA, PURPOSES, AND LEGAL BASES
   On the occasion of using the site https://san-fernando.ec/, certain personal data may be collected.

Purposes Categories of collected data
Legal basis
Retention durations
Management of information requests and contact Through the contact form: identity and contact details Legitimate interest of SAN FERNANDO Duration necessary for the processing of requests,
Up to 3 years from the last request / last contact with the concerned person

In general, all data from our clients are also collected for accounting management, invoicing, and collection of SAN FERNANDO’s receivables, based on our legal obligations, our contractual relationships, or our legitimate interest.
Before the collection of data, you will be informed if the personal data requested must necessarily be provided or if they are optional.
Data identified by an asterisk in forms are mandatory. Failing to provide them, access to the Services and their use by the concerned person will be impossible, or a request related to a form cannot be satisfied.
Other data are optional, and their non-provision will not compromise the delivery of promised services or responses to information requests, although it may limit their relevance.

4. DATA RECIPIENTS, AUTHORIZED THIRD PARTIES, AND PROCESSORS
   The data recipients are as follows:

Processes involved Recipients
Management of information requests and contact
SAN FERNANDO

Authorized third parties:

SAN FERNANDO reserves the right to transmit your personal data to comply with its legal obligations, especially if it is compelled by judicial requisition.

In accordance with the current regulations, your personal data may be transmitted to organisms, auxiliary of justice, and ministerial officers authorized by a legislative or regulatory provision, in the context of a specific mission or the exercise of a right of communication.

When SAN FERNANDO faces a request for communication from a third

party based on a text, we ensure that the advanced provision is in force, and that it actually provides a right of communication for the requester.

SAN FERNANDO ensures to transmit only the data provided by the text or, in case of imprecision of the latter, only the data that appear strictly necessary to achieve the sought goal.

The communication of the data will be carried out in a way that ensures their security, adapting the measure retained to the nature of the data and the risks present.

Processors:

In the case where SAN FERNANDO entrusts data processing activities to processors, only processors presenting sufficient guarantees regarding the implementation of appropriate technical and organizational measures are chosen, so that the processing meets the reliability and security requirements demanded by the applicable regulation and ensures the protection of the rights of the persons.

No personal information of the user of the site https://san-fernando.ec/ is published without the user’s knowledge, exchanged, transferred, assigned or sold on any support to third parties. Only the hypothesis of the buyout of SAN FERNANDO and its rights would allow the transmission of said information to the possible purchaser, who would in turn be bound by the same obligation of conservation and modification of the data with respect to the user of the site.

5. SECURITY MEASURES
   Given the evolution of technologies, implementation costs, the nature of the data to protect, and the risks for the rights and freedoms of persons, SAN FERNANDO implements all appropriate technical and organizational measures to ensure the confidentiality of personal data collected and processed and a level of security adapted to the risk, including:

• A health data certified host for our care software
• Fighting against malicious codes (viruses, spyware, software bombs…)
• Protection of computer channels (networks)
• Backups
• Data compartmentalization
• Encryption

As part of security measures, the site uses an SSL certificate. This is symbolized by the padlock present on the address bar. This guarantees that the information transmitted between your browser and our site is secured.

SAN FERNANDO staff and collaborators are also made aware of the protection of personal data.

6. TRANSFER OUTSIDE THE EU
   Personal data are not transferred outside the European Union.
   Some integrated functionalities on the site may collect data intended for servers in the United States. The transfer of these data is governed by the Data Privacy Framework.
7. RIGHTS EXERCISE
   In accordance with the “Data Processing and Liberties” Law of January 6, 1978, as amended, and the Regulation (EU) 2016/679 relating to the protection of personal data, you have the following rights over your data: right of access, right to rectification, right to erasure (right to be forgotten), right to object, right to limit processing, right to portability, under the applicable conditions depending on the concerned processing.

You can also set directives relating to the conservation, erasure, and communication of your personal data after your death.

When processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.

To exercise your GDPR rights, you can contact us:

• Via our contact form https://san-fernando.ec/

We thank you to specify the object of your request and the right(s) you intend to exercise. In case of reasonable doubt about your identity, a valid proof may be requested.

If you consider, after contacting us, that your rights over your personal data are not respected, you can file a complaint with the CNIL.

8. COOKIES
   When visiting our site, cookies (also called: connection witnesses) are placed on your device to perform audience statistics, improve your user experience, and offer you personalized content.
   Some cookies are mandatory because they ensure the proper functioning of our website, others require your consent.
   To adjust your preferences, you can use the cookie management panel.
   You also have the option to manage the cookies used on the site:

• By setting your browser* to accept or refuse cookies on a case-by-case basis before their installation.
• By regularly deleting cookies from your device via your browser.
• By installing a cookie manager to add, delete, modify, search, protect, and block cookies.
• By activating the private browsing mode or even the “Do Not Track” setting of your browser.
  *For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to change your wishes in terms of cookies.
  However, we inform you that by setting your browser to refuse cookies, some functionalities, pages, spaces of the site will not be accessible, for which we cannot be held responsible.
  We also draw your attention to the fact that when you oppose the installation or use of a cookie, a refusal cookie is installed on your terminal equipment. If you delete this refusal cookie, it will no longer be possible to identify you as having refused the use of cookies. Similarly, when you consent to the installation of cookies, a consent cookie is installed. The consent or refusal cookies must remain on your terminal equipment.
  Cookies allow to keep, during the validity of the concerned cookie, state information when a browser accesses the different pages of a website or when this browser later returns to this website.
  Several types of cookies may be used by the site:

Functional cookies
Functional cookies are necessary for the operation of the website. Functional cookies are essential for the operation of the site and for users’ navigation on it. They allow people to use the main functionalities of the sites and secure their connection.
These cookies have a very short lifespan, for the duration that the session remains active.
Without these cookies, users will not be able to use the site normally, and it is therefore advised against preventing their use or deleting them.

Audience measurement cookies
Audience measurement and statistical cookies allow us to know the use and performance of the sites, to establish statistics, attendance and usage volumes of various elements (visited content, pathways…) to improve the interest and ergonomics of the services offered (the most frequently consulted pages or sections, the most read articles…). These cookies also serve to measure the site’s consultation traffic.
For some of these cookies, the IP address (the only data related to the identification of the Sites’ visitors in this context), is anonymized by removing the last octet.
The lifespan of audience measurement cookies is limited to thirteen months.
Refusing to implement such cookies or deleting them does not affect the navigation of people on the sites, but is likely to prevent SAN FERNANDO from ensuring the improvement of the quality of services offered to visitors of its sites.

9. LIMITATION OF LIABILITY
SAN FERNANDO cannot be held responsible for the accuracy and relevance of the information published online by the user.

10. MODIFICATION OF THIS POLICY
In case of modification of this policy by SAN FERNANDO or if the law requires it, it will be published on our site and will be effective from its publication. Therefore, we invite you to refer to it during each visit to be aware of its latest version available permanently on our Site.