This document outlines the various measures implemented by the INA to ensure, in accordance with (EU) Regulation 2016/679 known as the General Data Protection Regulation (“GDPR”) and law no. 78-17 known as the “Data Protection and Freedom of Information Act” of 6th January 1978 amended, protection of personal data You have sent to us when browsing on the INA website, hereinafter referred to as the “Website” as defined within the General Terms and Conditions of Use.

If you wish to access certain services provided by the Website, such as Account creation and administration, information requests using our contact form or subscription to our newsletter, you will be asked to provide us with personal data.

We limit the collection of personal data to that which is strictly necessary (data minimisation) and we only use these data for provision of those services which you have accepted.

Consequently, your personal data are likely to be processed by the INA in the capacity of data controller for the following purposes:

1. User Account creation and administration:

Account creation and administration is a form of processing managed by the INA in accordance with the terms and conditions defined hereunder:

1. 1. Purpose, legal basis and category of data processed

   In accordance with our General Terms and Conditions of Use (T&Cs), when you open an account you will be able to access the Website Services. When creating your account, we ask you to provide us with data regarding your civil status and professional details.

   This processing allows the INA to manage orders of content on the Website and to have statistics regarding Website services.

   The legal basis for processing is performance of a contract, with Account creation being subject to prior acceptance of our T&Cs.

2. 2. Mandatory nature of data collection: data collected are those which are strictly necessary and failing provision of all data indicated as mandatory on the contact form, the Account creation request cannot be processed.

3. 3. Data subjects: processing concerns natural persons and legal entities asking to open an account.

4. 4. Data recipients: data are intended to be sent to the INA Marketing and Sales teams.

5. 5. Data transfer outside of the European Union: no data is sent outside of the EU.

6. 6. • Term of data storage: data are stored for the entire term of contractual relations (for as long as your Account exists) and then archived for a term corresponding to legal requirements.

2. Management of newsletter subscriptions on the Website:

The newsletter distribution services is a form of personal data processing managed by the INA in accordance with the terms and conditions defined hereunder:

1. 1. Purpose, legal basis and category of data processed: insofar as you have chosen to receive our newsletter, we will use your personal data (email address) in accordance with the terms and conditions appearing herein so as to keep you informed by email of any changes and developments to our products and services. However, when we collect any personal data likely to be used to keep you informed regarding our products and services, you will be given the opportunity to accept or refuse use of your personal data for commercial marketing operations.

2. 2. The categories of data processed are as follows: email address, date of subscription/unsubscription, IP address.

3. 3. Mandatory data collection: collection of an email address is mandatory in order to issue newsletters.

4. 4. Data subject: data processing only concerns those people who wish to register on the Website to receive the INA newsletter.

5. 5. Data recipients: data are intended to be sent to the INA Marketing and Sales teams.

6. 6. Term of data storage: each email we send includes an unsubscription link which allows you to automatically stop receiving these emails. The INA stores your email address for 3 (three) years following the last date of contact with you. If you should decide to unsubscribe using the unsubscription link provided, you will be removed from the corresponding distribution list within a reasonable timeframe.

7. 7. Data transfers outside of the European Union: your personal data may be transferred to an INA service provider located in the USA for newsletter administration purposes. The recipients will receive the following data: name, email address, IP address, unsubscription and consent data, behavioural data. As the USA is not the object of any adequacy decision by the European Union, a cross-border data flow agreement which complies with Standard Contractual Clauses of the European Commission has been signed with this company in order to govern data transfers and provide a sufficient level of protection in light of the GDPR Regulation and Data Protection and Freedom of Information Act.

3. Management of requests sent using the Website contact form

The Website contact form is a type of personal data processing managed by the INA in accordance with the terms and conditions defined hereunder:

1. 1. Purpose, legal basis and category of data processed: processing is intended to manage Website User requests. This notably allows for electronic receipt of requests made using our online contact form and their archiving. This processing allows us to respond to your request. The categories of data we process are: data regarding your civil status, contact details (email address), professional details, the subject of the request, the date and number of the request, as well as the response provided.

2. 2. Mandatory nature of data collection: collection of data marked by an asterisk is mandatory for proper processing of a request.

3. 3. Data subjects: data processing concerns Website Users wishing to send a request regarding the Website.

4. 4. Data recipients: data are intended to be sent to the INA Marketing and Sales teams.

5. 5. Term of data storage: User requests and responses provided are stored for 3 years following the last date of contact with Users.

6. 6. Data transfer outside of the European Union: no data is sent outside of the EU.

Personal data collected on our Website will not under any circumstances be distributed, assigned, leased or exchanged by the INA to any third parties without your prior consent.

Nevertheless, to comply with legislative and regulatory requirements, your personal data may be sent to the competent authorities.

The INA undertakes to protect your personal data by applying standard encryption technologies to encode information sent online. These various forms of security technology and procedures are intended to protect your personal data and prevent any unauthorised persons from access, use and disclosure thereof.

The INA may not be held liable for the content of other websites to which any links appearing on our Website may redirect, their level of security or privacy practices applied.

In accordance with and within the limits of the provisions appearing in the (EU) European Regulation 2016/679 and law no. 78-17 of 6th January 1978 amended known as the “Data Protection and Freedom of Information Act”, you have a right of access, amendment, deletion, limited processing of your data, objection, right to portability of your data and the right to issue instructions for use of your personal data after death.

You can exercise these rights by sending an email to dpdina@ina.fr or by writing to the attention of the Data Protection Officer, Legal Directorate, located at 4 avenue de l'Europe 94366 Bry-sur-Marne Cedex, along with a copy of a valid ID document. You finally have a right to make a claim with the National Data Protection Authority (CNIL).

When browsing on our Website, we may install cookies on your computer, mobile device or tablet to improve interaction with our Website and our services.

1. What is a “cookie”?

A “cookie” is a string of information, generally small in size and identified by a name, which may be sent to your browser by a website when you connect. Your web browser will store this for a certain period of time, and send it to the web service each time you reconnect.

Cookies have multiple purposes: they may be used to memorise your client identifier with a commercial website, content in your basket, an identifier to trace your browsing habits for statistics or publicity purposes, etc.

In order for our Website to be best suited to its users, we use cookies so as, for instance, to identify you to be able to access your Account.

When you visit our Website for the first time, a banner will be displayed to notify you of the presence of cookies and inviting you to indicate your choice. Cookies are only installed if you accept.

At any time, you may find information and change settings for cookies to accept or refuse their use by visiting the COOKIES MANAGEMENT page.

You can indicate your preferences for the entire website overall, or for each individual service individually.

The majority of cookies may also be managed by the web browser you use.

The information which we have published in this charter allows you to better understand how cookies work and how to use tools to adjust their settings.

2. Different parties issuing cookies

INA cookies: these are cookies installed on your workstation by the INA for the purposes of browsing on our Website.

Third-party cookies: these are cookies installed by third-party companies to measure visitors to our Website. These third-party cookies may be installed whenever you browse on our Website. The INA does not always manage third-party cookies installed by partners who operate on their own behalf. Where applicable, and insofar as practically possible, we refer to tools provided by our partners to manage third-party cookies.

3. Different types of cookies

Different types of cookies are used on our Website, they each serve different purposes. Some are necessary for proper operation of the Website.

Essential cookies: cookies which allow for optimal operation of the website. These allow you to use the primary website functions (namely to log in to your Account). You can object and delete these through your web browser settings, however your overall user experience may be negatively affected. List of essential cookies installed on the Website:

Cookie name	Purpose	Term of storage
PHPSESSID	This cookie allows Website users to be identified	Expires at the end of the browsing session*
Form_Key	This cookie adds a random string to all form submissions to protect data against cross site request forgery (CSRF).	Expires at the end of the browsing session*
Mage-cache-sessid	This cookie triggers local cache storage cleaning	Expires 24 hours after creation
Mage-cache-storage	This cookies forces local storage of specific sections of content which should be invalidated	Expires 24 hours after creation
Mage-message	This cookie tracks error messages and other notifications displayed to users, such as the cookie consent message and various other error messages.	Expires 24 hours after creation

*Once your session is over (after the browser has been closed), the cookie will be deleted.

Functional cookies: these are notably cookies which allow for customisation of your browsing experience on the Website. These cookies allow you to use the Website in the simplest and most effective manner possible, for instance by storing your preferences regarding the type of information you wish to receive (for example storage of your language display settings, products stored in your basket, etc.).

Cookie name	Purpose	Term of storage
Mage-translation-file-version	This cookie facilitates the translation of content into other languages	Expires at the end of the browsing session*
Mage-translation-storage	This cookies stores the translated content at a client’s request.	Expires at the end of the browsing session*
Private_content_version	This cookie adds a random number and time to static pages to prevent these from being cached on the server	Expires 10 years after creation
Product_data_storage	This cookie stores information regarding articles	Expires 24 hours after creation
Recently_compared_product	This cookie stores information regarding back clicks to compare products	Expires 24 hours after creation
Recently_viewed_product	This cookie stores information regarding products already seen by users	Expires 24 hours after creation
Recently_viewed_product_previous	This cookie allows you to return to a product already seen by the user	Expires 24 hours after creation
Section_data_ids	This cookie stores specific client-related information regarding actions undertaken by the client, such as the display of wish lists, payment information, etc.	Expires 24 hours after creation
Sidebar_collapsed	This cookie is used as a reminder if the side bar on the page is collapsed	Expires 10 years after creation

*Once your session is over (after the browser has been closed), the cookie will be deleted.

Audience statistics cookies: these are third-party cookies which provide us with details regarding use and performance of our Website (for instance to know the most frequently visited pages, user searches in our Website search engine, etc.). In addition to analysing visitors, they also allow us to detect any potential browsing issues and to consequently improve the usability of our services. The lifetime of these audience statistics cookies does not exceed 13 months. The Website uses Google Analytics to generate the following cookies:

Cookie name	Purpose	Term of storage
_ga	This cookie allows website users to be identified	Expires 13 months after creation
_gid	This cookie allows website users to be identified	Expires 24 hours after creation
gat	This cookie optimises requests	Expires 1 minute after creation

You can, however, object to installation of Google Analytics cookies on your workstation at any time by clicking on the following link: https://tools.google.com/dlpage/gaoptout?hl=fr+

Advertising cookies: these are cookies used to display ads or send you information which is compatible with your interests on the website of a third-party editor or outside thereof whenever you browse online. They are particularly used to limit the number of times you see an ad and help to measure the effectiveness of an ad campaign. Refusing these advertising cookies has no impact on use of our Website. However, if you refuse advertising cookies, this will not stop ads from being displays on the website of a third-party editor nor when using the Internet. This will simply lead to ads being displayed which are not suited to your interests or preferences. These cookies are third-party cookies which depend on advertisers. The INA does not use these on this Website.

Social media cookies (social media buttons): these are third-party cookies which make it easier to share pages and content across various social media platforms. These will, for instance, allow you to like and share information from a website with friends on social media. Social media buttons may use cookies to monitor users’ browsing habits, whether or not you use these platforms, and whether or not you are connected to the social media account when browsing. These cookies also allow for targeted ads to be displayed across these platforms. The INA does not use this type of button on its Website.

4. Accepting or refusing cookies

You have various ways of managing cookies.

In your browser settings: when you first visit our Website, the INA informs you of the use ofx cookies and their purpose with the display of a banner informing you how to deactivate cookies. At any time, you can choose to delete all cookies stored on your computer to permanently erase the information they contain. Your browser may also be set up to inform you that cookies are stored on your workstation and ask whether or not you accept them. You can either accept or refuse cookies on an individual basis or automatically refuse them all. However, settings may change how you can access our Services which require the use of cookies. If your web browser is set up to refuse all cookies, you cannot use the essential functions of our Website, such as for example accessing your Account. To manage cookies as closely as possible to your expectations, we invite your to adjust your browser settings in line with the purpose of cookies as indicated above. The settings for each browser are different. These are indicated in the help menu of your web browser, which will show you how to change your cookie settings. You can deactivate cookies by following the below instructions using the settings of your web browser:

1/ if you use Internet Explorer https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies

2/ if you use Firefox https://support.mozilla.org/fr/kb/activer-desactiver-cookies

3/ if you use Safari https://support.apple.com/kb/PH19214?viewlocale=fr_FR&locale=fr_FR

4/ if you use Google Chrome https://support.google.com/chrome/answer/95647?hl=fr

Settings on a cookie management platform: at any time you can change your cookies settings to accept or refuse their use by visiting the COOKIES MANAGEMENT page. You can indicate your preferences for the entire website overall, or for each individual service individually.

This document may be updated. In this instance, we will indicate the date of the most recent update at the top and bottom of the document. Your consent will be automatically required if the updated version of this confidentiality notice affects the rights of use of your personal data in any manner in relation to the provisions appearing in this document at the time information is collected.

 

Valid from: May 2020