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Cookies Policy & Configuration

This section describes how cookies are used by SQUARE SA group-managed websites. It will help you gain a better understanding regarding the origin and usage of the browsing information analyzed when you consult our sites as well as your rights in this matter. This page thus serves two purposes: it allows you to have a positive and confident experience while using our services, and it enables us to precisely and fully answer any questions you may have about consulting our websites, in addition to taking your needs and concerns into consideration.

In application of the European directive, the “Telecoms Package,” you must be informed and give prior consent before cookies and trackers can be dropped on to your device.

Within this framework, you have the possibility to refuse trackers when you visit a website or use an application.

Your prior consent regarding the use of cookies and trackers is valid for a maximum of 13 months.

Additionally, it is explained that, in accordance with the applicable regulations, certain trackers do not need your consent to be used.

In order for you to be completely informed and make free and educated decisions, a summary of the applicable rules appears hereafter.

What is a cookie or tracker?

The aforementioned regulation concerns trackers that are dropped and identified, for example, when a person looks at a website, reads an email, installs or uses software or an application, whether it be on a computer, Smartphone, digital reader or an online video game console. As such, the term “cookie” covers the following:

  • HTTP cookies,
  • “flash” cookies,
  • the outcome of identifying a device when using a “fingerprinting” method (registering a device’s unique identifier based on its configuration for tracking purposes),
  • invisible pixels or “web bugs,”
  • any other identifier generated, for example, by a software or operating system.

These are all tracking methods, whether or not the cookie collects personal information.

Cookies can have many purposes. Regardless of the type of cookies used, only the cookie issuer can identify or modify the information that it contains.

What is the legal framework?

Through the adoption of directive 2009/136/CE, European legislation changed the former legal framework (article 5(3) of directive 2002/58/CE) and mandated that a user must give prior consent before information regarding their device can be stored or already stored information can be accessed.

The only exceptions to this rule are if these actions are strictly necessary for the deliverance of a service expressly requested by the subscriber or user.

The transposition of the 2009/136/CE directive into French law took place via ruling #2011-1012 from August 24, 2011, having modified article 32-ll of the “Information and Liberty Law” from January 6, 1978.

Which cookies require prior notification and consent?

As a matter of principle, the cookies requiring prior notification and consent can be, but are not limited to:

  • cookies related to targeted advertising campaigns;
  • certain audience measurement cookies (see the exemptions below);
  • cookies from social networks generated via share buttons collecting personal information without your consent.

The law indicates that certain trackers do not need your consent to be used.

Cookies for Audience Measurement Solutions (Analytics)

In order for audience measurement cookies to be exempt from prior consent, they must respect the following conditions:

  • notification must be given so that you can object to its usage (a user must be able to object from any kind of device);
  • information collected must not be corroborated with other information (client files or traffic statistics from other websites, for example);
  • the dropped tracker can only be used to create anonymous statistics and cannot monitor browsing on different sites. It must not be saved for more than 13 months and cannot be extended with new visits;
  • raw traffic data that includes identification information can also not be saved for more than 13 months;
  • an IP address used for geolocation is not allowed to identify your street: only the first two octets of the IPv4 address can be kept and potentially used for geolocation (for IPv6 only the first 6 octets can be saved).

The analytics solutions that do not respect the above conditions must receive your prior consent before being used.

THE DIFFERENT TYPES OF COOKIES USED ON E-BISCUS GROUP-MANAGED WEBSITES

  • Cookies used for Essential Purposes

These cookies are essential for our website to function. Without them, it would not be possible to access our content or services.

  • Audience Measurement Cookies

These cookies allow us to keep track of the number of people who visit our site and identify how they use the site. The collected data allows us to continually improve your user experience.

The data selected does not allow us to identify a user, their information remaining anonymous.

  • Cookies that we use on our Advertising Space

Some cookies are likely to be included in the advertising space on our websites. This advertising space displays advertising content from different companies. This space contributes financially to the content and services that we make available to you.

  • Social Network Cookies

By clicking on the share buttons on our websites, cookies can be dropped on to your device. For example, share buttons from Facebook TM, Twitter TM, Google +TM and YouTube TM.

Even without clicking on these buttons, social networks can follow your browsing on our websites and thus collect data. It is impossible for us to monitor the information collected.

Depending on your interests, the information collected will influence which advertisements are displayed on these social networks.

It is possible to object to the use of such cookies, but you will no longer be able to take advantage of the share button features.

Here is the list of cookies used by social networks according to their software publisher:

For more information, please consult the privacy protection policy for these social networks.

You can also manage certain cookies from the YourOnlineChoices platform: http://www.youronlinechoices.com/fr/controler-ses-cookies/.

How do these websites obtain my consent?

According to the “Information and Liberty Law,” as long as you have not given consent, cookies and trackers requiring consent cannot be dropped or identified on your device.

Giving consent is an expression of a free, specific and informed choice.

Within this framework, you have the choice to accept or refuse the use of cookies or trackers.

Your refusal of cookies requiring your consent has no outcome on your access or use of the website at the following address https://www.togallcreatorstogether.com

Consent must be given for each application and website and it is required each time a new objective is added to the initially planned objectives.

Here are the steps to obtain your consent, according to the CNIL’s recommendations:

STEP 1: Prior notification

As soon as you go to the website at the following address https://www.togallcreatorstogether.com (home or secondary page on the website), a pop-up banner appears and informs you of the following:

  • The exact objectives of the cookies used;
  • The possibility to object to these cookies and change the configuration by clicking on a link in the banner;
  • The fact that continuing to browse on the website will be considered as consent for dropping cookies on to your device.

As long as you have stopped browsing, in other words, as long as you did not go to another page or click on anything else (like an image, link, button, etc.), the aforementioned banner will remain. This is so that you are perfectly informed and your consent is not ambiguous.

Unless given prior consent, cookies cannot be dropped and identified:

  • If you go to the website (home page or another page on the site from a search engine, for example) and do not continue to browse (taking no further action cannot be construed as an expression of consent);
  • If you click on the link in the banner taking you to the page where you can configure the cookies and, if need be, refuse their use.

Attention: continuing to browse is considered as consent for dropping cookies on to your device.

STEP 2: “To Learn More – Cookies Configuration” Page

If you click on the link “To Learn More – Cookies Configuration,” you will be directed to the present page, which allows you to configure cookies and trackers.

This page allows you to refuse the use of cookies and trackers.

In order to do so, we have put into place practical solutions, which can be used on all of our tracking technology (cookies, flash cookies, fingerprinting, plugins, certain stored images in the browser, memory space specific to different browsers, etc.).

You can thereby freely accept or refuse the use of cookies by its function (advertising, social networks, audience measurement, etc.).

You can choose to give consent or object to cookies using the following methods:

  • Cookies configuration tool directly available on the website or application;
  • Redirect to tracking opposition tools proposed by either audience measurement, advertising or social network solutions; on the condition that these solutions must be user-friendly and operational on all devices and browsers. No information regarding internet-goers who have either not given their consent or have objected can be collected;
  • In certain conditions, the browser settings. Managing cookies and your options is different for each browser. To learn more, consult your browser’s help menu, which will instruct you on how to personalize the use of cookies on your device.

 

- For Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies,

- For Safari™: http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html,

- For Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647,

- For Firefox™: http://support.mozilla.org/fr/kb/,

- For Opera™: http://help.opera.com/Windows/,

 

In order to collect your prior consent, we have also put into place:

  • A banner indicating the objectives of the cookies used, explicitly asking if you would accept the dropping of cookies by type, all the while explaining the methods that we use in order to remove them at a later date (see below);
  • A superimposed consent request form;
  • Boxes to be checked when signing up for online services, which allows you to accept the use of cookies by objective;
  • Buttons that activate cookie dropping service features (for example, social network plugins).

How long is your consent valid?

According to the principle of the “right to be forgotten,” your consent must be able to be deleted.

Consequently, your consent to the use of cookies and trackers is valid for a maximum of 13 months, starting from when the cookies are first dropped on to your device after consent has been given.

Once this period has expired, you must once again give your consent.

In no case whatsoever, can your consent be prolonged due to subsequent visits to the website on your behalf.

How to retract your consent ?

In order for you to retract your consent at any time, as easily as you gave it, we have put into place the following easy-to-use solutions:

  • Cookie configuration tool directly available on the website or application
  • The interprofessional platform Youronlinechoices:

You can connect to the Youronlinechoices website, proposed by digital advertising professionals within the European association EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France.

You will consequently discover which companies are registered on this platform and those that allow you to refuse or accept cookies used for retargeting strategies:

http://www.youronlinechoices.com/fr/controler-ses-cookies/

This European platform is shared by hundreds of online advertising professionals and constitutes a centralized interface allowing you to refuse or accept cookies used for retargeting strategies. Please note that this will not stop advertisements from being displayed on websites that you visit. It will only block retargeting campaigns, which adapt its advertisements to your interests.