Last edited on January 31, 2024

This Privacy Notice (hereinafter the “Notice”) applies to the processing of data related to the use of the website of www.inits-group.com (hereinafter "the Website").

INITS Group and its affiliates (INITS) takes your privacy very seriously. We aim to be as honest and transparent with you on the use of the Personal Data we collect. We respect the privacy and the protection of personal data of our visitors and customers to build a sustainable relationship with you based on trust. For that purpose, we provide you this Privacy Notice that enables you to understand how we are committed to look after your Personal Data.

INITS as the Controller of the personal data, has committed to comply with: 

• The General Data Protection Regulation N°EU 2016/679 (hereinafter, the "GDPR"). 

• The French Law No. 78-17 of 6 January 1978 relating to data, files and freedoms, as amended by Law No. 2018-493 of 20 June 2018 on the protection of personal data.

• And all EU applicable laws and regulations regarding data protection.

Collectively referred as "Data Protection Laws". All terms relating to data protection must be interpreted in the light of the GDPR.
With this Privacy Notice, INITS wants to make sure that you understand what personal data is collected about you, how your personal data is used and how it is kept safe.

THE IDENTITY OF THE DATA CONTROLLER

The Personal Data collected on the website (inits-group.com) are processed by INITS GROUP SA, 209 Rue De La Pépinière 34000 Montpellier, France, registered under the number 792 300 238 RCS Montpellier B, duly represented by its President Amel Hadri.
INITS has appointed a Data Protection Officer (DPO), who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Address:

INITS- DPO
474 allée Henri II de Montmorency, Immeuble Carré Montmorency, 34000 Montpellier, France

E-mail: dpo@inits.fr  

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GENERAL WARNING AND USE OF SOCIAL MEDIA

Access to the Website implies your full and unreserved acceptance of this Privacy Notice, as well as its general terms of use and the Cookies Notice. You acknowledge having read the information below.

The Notice is valid for all pages hosted on the Website. It is not valid for the pages hosted by third parties to which INITS may refer and whose privacy notices may differ. INITS cannot therefore be held responsible for any data processed on these websites or by them. This Notice also applies to any other website that INITS may operate, including our Company pages on LinkedIn or Vimeo.

Please, note that for the use of social media, INITS will be Joint-Controller with LinkedIn only for the following activities: accessing and processing statistical aggregated data provided by LinkedIn. For any other processings on one of the social media platforms, the latter shall be considered as the sole Data Controller.

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OUR PRIVACY COMMITMENT

In order to preserve the confidentiality and security of your Personal Data, whether you are a client, a business partner, an employee, a candidate for a post or any other person whose Personal Data are processed, we take the following engagements: 

• We respect your privacy and your choices;

• We will send you marketing communications only with your consent for individuals;

• We will send you marketing communications for professionals unless you decide to be removed from our database. In this case, we are committed to do so as soon as possible;

• We will not Process your Personal Data in ways that we have not told you about;

• We will never sell your Personal Data;

• Your Personal Data  will be stored on secured servers and only transferred to authorized persons;

• We collect Personal Data strictly necessary for the realization of the contracted services or the defined purposes; 

• We store your Personal Data which are the subject of a computer processing on a secured and confidential server;

• We are committed to keep your Personal Data safe and secured with technical and organizational measures in accordance with the Data Protection Laws;

• We are committed to being transparent about how we collect and use information from you; 

• We respect your rights and will always try to accommodate your requests as far as possible, in line with our own legal and operational responsibilities;

• We have appointed a Data Protection Officer responsible for ensuring safety and protection of Personal Data (see contact details above);

• When collecting your Personal Data (during congresses, webinars, contact forms published on our websites, by an order placed with us, because of marketing subscription or by purchasing contacts from vendors, etc.) we and our trusted third parties (defined below) will use them in line with this Privacy Notice.

Note that all of the information from this Privacy Notice may not be applicable to you. We provide below an overview of all possible situations in which we could interact together. Please read this information carefully. If you need more information about our privacy notice or if you have questions about it, do not hesitate to contact our Data Protection Officer at dpo@inits.fr

THE PERSONAL DATA COLLECTED AND PROCESSED, LEGAL BASIS AND WHY WE NEED THEM

The collection and Processing of Personal Data is based on appropriate legal basis:

• Agreement: the Processing of Personal Data is necessary for the execution of the agreement to which you have agreed;

• Consent: you agree with the Processing of your Personal Data through an express consent;

• Legitimate interest: INITS has a marketing interest to Process your Personal Data. This interest is balanced and legitimate. Subject to exceptions, you can oppose to the Processing of your Personal Data based on this legal basis by writing to the addresses included in the contact section.

• Law: the Processing of your Personal Data is required by a law.

Therefore, we collect and Process the Personal Data relating to communication and marketing, as part of our legal and contractual obligations, as part of human resources and as part of our health activities.
 

SECTION 1: COMMUNICATION AND MARKETING  

We collect business and professional information to be used in our direct marketing, emails, E-newsletters, phone calls in order to market INITS’ products and services. Moreover, we use this information internally in INITS to improve customer experience, our website, marketing, sales and social media efforts. 
In the paragraphs below, we explain in what context your Personal Data are collected and how we Process them: we explain what activity you are involved in when we Process your Personal Data and what types of Personal Data we may collect when you are involved in this same activity.

Online browsing 
When visiting our website, your Personal Data are collected automatically by cookies (For information about cookies, please read the Cookies paragraph).  

Personal Data related to your use of our websites include:  

• where you came from;  

• pages you looked at: The titles and the URLs of the pages you are viewing;  

• duration of your visit: Date and time of visit;  

• your IP address (computer’s address);  

• device information: Regional and language settings (to determine country origin), operating system
  (Windows, OS X, Linus, iOS, Android etc.), Java and JavaScript support; and 

• visitor ID which is given to each visitor and the expiration date of the ID.

Social media browsing
We collect your Personal Data when you submit content on one of our social media platforms. Moreover, we gather social media statistics from the social media software platforms where INITS is present. Currently, this is LinkedIn and Vimeo. The information is used for analytics views: numbers of visitor, impressions, visits, mentions, numbers of like and followers.
 

Web-page contact forms / enquiries
We collect your Personal Data when you ask questions related to our products or activities or when we manage your enquiries from our websites contact forms.  

Personal Data related to your enquiries are: 

• First name and Last Name

• Email address

• Company/Institution name

Other information you have shared with us about yourself in relation with your enquiry 
 

Events (like symposium)
When you register for our events, like symposium during congress, we collect and store your participation data (e.g. contact and event participation details). Your consent is required while registering to symposiums.

E-newsletters & press releases
When you are registered in our database, you receive news about INITS like E-newsletters or Press Releases. This means that you accept to receive information by e-mail. INITS sends newsletters and emailing only to people listed in its database.

We collect and track newsletter performance by analyzing the opening rates, click rates etc. Your consent is required while registering to our E-newsletters and press releases. If you decide not to receive our emailing anymore, you can at any time opt out with the “unsubscribe” link at the foot of any email from INITS.
 

SECTION 2: HUMAN RESOURCES

INITS collects and processes its employees’ Personal Data, as well as the Personal Data of applicants for a job in the company.  
The Personal Data collected under this process are, in particular, the civil status, the surnames and family names, gender, address, banking data, identification document and social security number.

LENGTH OF CONSERVATION OF YOUR PERSONAL DATA 

As for the Personal Data collected on the basis of the legitimate interest, INITS has a marketing  interest to Process your Personal Data. This conservation of Personal Data will be time limited according to legal obligations.. You can oppose at any moment to the Processing of your Personal Data collected on the basis of the legitimate interest by sending a message to the addresses mentioned in the contact section.
As for the Personal Data collected on the basis of a consent, you can remove your consent at any moment by simply sending a message to the company to the addresses mentioned in the contact section.

HOW DO WE PROTECT AND SAFEGUARD YOUR PERSONAL DATA? 

All the information collected on the INITS website are treated in a confidential manner and are stored in secure environments.  Your personal data are contained behind secured networks and are only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.
 

SHARING OF PERSONAL DATA 

We do not sell or share your Personal Data to third parties.  

YOUR RIGHT AS A DATA SUBJECT

Please note that you can exercise the following rights, at any time, subject to limitations as set forth in applicable Data Protection Laws:

• To be informed and to request access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, you can request to receive information from INITS about your Personal Data we have in our database and how we use it. You can also receive a copy of this Personal Data.

• To ask for rectification and / or completion: You have the right to ask for Personal Data rectification if these data are incorrect or completion if they are incomplete.

• To ask for erasure (‘to be forgotten’): In some cases, your Personal Data can be erased or deleted. This might be the case:  
  o    If you withdraw your consent.  
  o    If you think that your Personal Data are no longer necessary for the purpose for which they have been collected, you can request their deletion.  
  o    If your Personal Data were processed unlawfully, contrarily to other legal obligations or for a purpose that differs from what has been initially explained to you
  o    If you object to the Processing of your personal data

• To require restriction of Processing: You have the right to require the restriction of your Personal Data Processing if one of the following conditions, set out in the Data Protection Laws, is met:
  o    the accuracy of the Personal Data is contested by you for a period which allows us to verify the accuracy of this information;
  o    the Processing is unlawful and you refuse the deletion of the Personal Data and request that we restrict them instead;
  o    we no longer need your Personal Data for Processing purposes, but you required them for the establishment, exercise or defense of legal claims. 
  o    you object your Personal Data processing being based on our legitimate interests, and it is not yet clear whether our legitimate reasons prevail over yours.  

• To object to the Processing: You have the right to object to the Processing of your Personal Data on the ground of compelling legitimate grounds relating to your particular situation. If your objection is justified, we will stop to Process your Personal Data.

• To request data portability: You have the right to move, copy or transfer Personal Data from our database to another or to transmit those data to another person without hindrance. You can also request to receive your Personal Data, which you have provided to us, in a structured, common and machine-readable format. 

• To withdraw your consent: You have the right to withdraw your consent to our Processing of your Personal Data when such processing is based on consent. The withdrawal of your consent does not affect the lawfulness of our processing until the consent withdrawal.

• To lodge a complaint with a supervisory authority: You have the right to complain to a supervisory data protection authority (In France, the Commission Nationale de l’Informatique et des Libertés (CNIL), website: www.cnil.fr) of your habitual residence, place of work or place of alleged infringement about our data protection and privacy practices.
  Please note that there are exceptions to the various rights listed above. For example, we have a legal obligation to keep some of your Personal Data. 

We shall respond to your request within a period of a month. When your request is particularly complex, we have two additional months for a response. 
INITS has a Data Protection Officer in charge of the protection of your Personal Data. 
You can contact the Data Protection Officer at the following address: dpo@inits.fr 

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THE TRANSFER OF YOUR PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Your Personal Data may be transferred for various purposes listed above to countries in the European Economic Area.

When sharing your data involves a transfer of Personal Data Outside EEA, INITS undertakes to only transfer your Personal Data to countries with an adequate security level or to implement appropriate safeguards ensuring the protection of your Personal Data (for instance Standard Contractual Clauses, BCR, etc.) 
INITS will take all technical and organizational measures necessary to secure these transfers of Personal Data. Transfers of Personal Data to third countries (for example, in the United States of America) can be achieved especially when INITS, due to its contractual obligations, works with counterparties located outside the European Economic Area.

Transfers of Personal Data to other Data Controllers, Subcontractors or Sub-processors 

INITS has concluded or will conclude appropriate written agreements with its contractors, to ensure that they Process your Personal Data in accordance with the instructions of INITS and they apply and maintain a level of appropriate security to the Personal Data. The transfer is done using mechanisms recognized as compliant by the European Commission.

Transfers to third parties
INITS may only be required to disclose your Personal Data to protect the rights that it is granted by the law.

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THE COLLECTION OF CHILDREN'S PERSONAL DATA

Legally in Europe, minors under 13 years cannot, in no case, give themselves their own consent to the processing of their Personal Data. In France, a minor under 15 years may not consent to the treatment of his Personal Data. 
INITS is committed to protecting the Personal Data and the privacy of children and does not Process children’s Personal Data. If the parents and/or legal guardians of a minor discover that the latter has provided Personal Data to INITS, they are invited to apply for the deletion of the Personal Data collected by sending a mail or an email to the addresses indicated in the present Privacy Notice.

CONTACT INITS

For any question or query about this Privacy Notice or requests relating to your Personal Data, you can write to us at the following addresses:

INITS GROUP-DPO
•    Address: 474 allée Henri II de Montmorency, Immeuble Carré Montmorency, 34000 Montpellier, France    
•    DPO email address : dpo@inits.fr   

CHANGES TO OUR PRIVACY NOTICE 

This Notice will be regularly reviewed and updated. If we decide to change or update our Privacy Notice, we will do so on this page. Please refer to this Notice on a regular basis.
In case of contradiction between several versions of the Privacy Notice, the latest version will prevail.