The purpose of this document is to explain to you the conditions under which the company TOORERS (hereinafter "TOORERS") manages the personal data (hereinafter the "Data") of visitors (hereinafter the "Visitors ") of the website accessible under the main address www.TOORERS.com, as well as in the spaces reserved and published by the Publisher on social networks, such as Linkedin (hereinafter the "Site"), and other from customers who also subscribe to a TOORERS service offer (hereinafter the "Customers"), in accordance with the requirements of the Data Protection Act of January 6, 1978 and Regulation (EU) 2016/679 of April 27th 2016 on data protection (GDPR).
The TOORERS personal data management policy may be updated according to legal developments and/or the processing of personal data carried out by TOORERS. Customers and Visitors are therefore advised to regularly refer to the latest version of the General Conditions of Use, which is permanently available on the Site.
The new clauses will govern all relations between the parties for the future, and only the new version will prevail between them, the applicable conditions always being those accessible online on the Site.

Last update: January 04, 2023

1. DATA CONTROLLER

1. TOORERS is responsible for the processing of personal data implemented through the Site, within the meaning of Article 1 of the GDPR.
Company TOORERS (hereinafter “TOORERS”)
SAS with a capital of 20000€
RCS PARIS B 922 046 776
Code APE: 7990Z (other reservation services and related activities)
VAT #: FR70922046776
Headquarters: TOORERS SAS, 27 rue de la Cour des Noues, 75020 PARIS
Director of the publication : Alejandra MARC (alejandra[@]TOORERS.com)
Website: www.TOORERS.com
E-Mail: booking@TOORERS.com
Téléphone : +33 7 66 78 85 37

2. COLLECTED INFORMATION
1. We only collect and process information that you communicate to us directly when you use our Site or when you subscribe to one of our service offers, namely when:
● You subscribe to one of our service offers,
● You contact us by phone, by e-mail or even through the social networks on which we are present,
● You subscribe to our newsletter,
● You participate in a contest,
● You are responding to a survey.
If the communication of your personal information is voluntary and subject to your consent, we may however be unable to provide you with certain services or information, if you do not provide all or part of the information requested.
2. The categories of information we collect include:
a) The identification and contact information (such as surnames, first names, postal address, means of contact) necessary for your identification,
b) The transactional information necessary to process your orders for services (chosen services, billing address, e-mail address, method of payment, etc.),
c) Personal information concerning you, including where applicable that of third parties, necessary in the context of the implementation of the services that you will order from TOORERS and in particular in the context of the training services delivered by TOORERS – it is reminded here that you must, before communicating the personal data of the employees and collaborators concerned, have obtained from them their consent to communicate their personal data to TOORERS.

3. The data that we request from you and which is essential to respond to your requests is identified by an asterisk or an equivalent process on the collection forms, or specified as such orally at the time of their collection. If you do not fill in the mandatory fields or do not provide the information marked as mandatory, we will not be able to respond to your requests, and in particular to process your service orders.

3. BASIS AND USE OF COLLECTED INFORMATION
The collection of personal data described under article 2 above are carried out because they are, cumulatively or alternatively:
A. Performed on the basis of your consent
The personal data concerning you, as well as those relating to third parties (see § 2.1.2.c) are collected on the basis of your consent.
B. Necessary to perform service contracts with you.
We also use your data to meet our contractual obligations, in the context of the conclusion and execution of service contracts concluded with you, and in particular for:
● Provide you with the services you order from TOORERS, process transactions and invoicing;
● Offer and manage any other service, current or future.
A. Necessary to meet the legitimate interests of TOORERS
a) Dynamically manage and animate the relationship with our Clients, enhance the image of TOORERS and publicise our services, including carrying out surveys.
b) Carry out studies and statistics.
We are likely to use the information collected for study and statistical purposes, after having made it anonymous.
B. Necessary to comply with our legal obligations Data concerning you is kept and archived to meet our legal obligations, in particular in accounting and tax matters, as well as to ensure the defence of our interests in the event of litigation or action in justice.

4. STORAGE TIME OF YOUR DATA
Your Data will only be kept by TOORERS for the time necessary to fulfil the purposes described in article 3 above, plus the legal limitation period.
If you are a TOORERS Customer, i.e. if you have ordered services, we will keep your Data, including, where applicable, those of third parties (see § 2.1.2.c), for the entire duration of the execution of the said services. , increased by a period of one (1) year from the date of provision of the last service.
This Data may be kept for longer, under specific legal obligations or with regard to the applicable legal limitation periods. For example, data may be retained for:
● 6 years for tax documents;
● 10 years for accounting documents;
● Throughout the duration of the litigation and until all remedies have been exhausted.
If you are not a Client but have nevertheless subscribed to our newsletter, we will keep your e-mail address until the date of your unsubscription from the newsletter.

5. DATA SHARING WITH THIRD PARTIES
To achieve the purposes described in article 3 above and within the limits necessary for the pursuit of these purposes, your Data may be transmitted to all or part of the following recipients:
a) Persons authorised within TOORERS (e.g. departments in charge of marketing, studies and analyses, customer service, litigation, accounting and tax affairs or IT and information systems security).
b) Agents of TOORERS who must necessarily have access to your Data for the performance of their duties (lawyers, chartered accountants, etc.), our advisers, or even third parties authorised by law, to enable us to ensure the collection of our debts, management of disputes, prevention of non-payment and litigation.
c) TOORERS service providers and subcontractors involved, for example, in the following operations:
● IT services,
● Site management,
● Fight against fraud,
● Customer relationship management.
d) The administrative or judicial authorities where necessary in the context of compliance with our legal obligations or to enable us to defend our rights and interests.
In the event that all or part of the activities of the TOORERS company are transferred, your Data will be communicated to the purchaser in order to ensure the continuity of the activity of the Site and the services provided by TOORERS.

6. PERSONAL DATA SECURITY
We implement the appropriate technical, physical and organisational measures to preserve the security and confidentiality of the Data and to prevent it from being distorted, damaged or accessed by unauthorised third parties.
We choose subcontractors or service providers who offer guarantees in terms of quality, security, reliability and resources to ensure the implementation of technical and organisational measures, including in terms of processing security.
We ensure, where applicable, that our service providers and subcontractors present guarantees and implement sufficient security measures to ensure the protection of the Data whose processing is entrusted to them in accordance with the requirements of the legislation on the protection of personal data. .

7. DATA RELATED RIGHTS
In accordance with the provisions of the Law of January 6, 1978 and Regulation (EU) 2016/679 of April 27, 2016 on data protection (GDPR), and within the limits set by these provisions, you have the following rights on the Data concerning you :
a) Access to your Data: Exercising this right allows you to receive a copy of the Data we hold about you and to verify that we are processing it in accordance with applicable legislation. b) Rectification of your Data: Exercising this right allows you to correct any incomplete or inaccurate information that we hold about you. You also have the possibility of requesting the correction of the Personal Data concerning you which would be incorrect and the limitation of their treatment at the time of their correction.
c) Deletion of your Data: Exercising this right allows you to ask us to delete your Data if we have no legitimate reasons to continue processing it. Your Visitor Account must, if necessary, be closed and any subscription to our newsletter terminated.
You can also request the erasure of your personal data in the following cases:
● You consider that our processing of your Data concerning you is no longer necessary, or that the achievement of the purposes referred to in this policy or that their storage is contrary to the law,
● You have withdrawn your consent to the processing of your Data,
● You object to the processing of your Data,
● You object to the use of your Data for commercial prospecting purposes.
d) Opposition to the processing of your Data: when the legal basis of the processing is in our legitimate interest, you can at any time oppose the use of your Data for reasons relating to your particular situation. In the event of the exercise of such a right of opposition, we will cease the processing except when there are legitimate and compelling reasons for the processing which prevail over your interests, rights and freedoms or for the recognition, exercise or the defense of a legal claim. You can also object to any processing related to commercial prospecting, or withdraw your consent at any time, in cases where it would have been requested from you (the withdrawal of your consent will have no impact on the lawfulness of the processing carried out before the withdrawal of consent).
e) Limitation of the processing of your Data: Exercising this right allows you to ask us to restrict the processing of Data concerning you. f) Portability of your Data: The exercise of this right allows you to receive the Data that we process concerning you, in a structured, commonly used and machine-readable format and to transmit them to another data controller without us getting in the way. We draw your attention to the fact that even in cases where you have asked us to benefit from your right to the erasure or limitation of the processing of your Data, we are likely to keep certain Data concerning you when the law requires us to do so. or authorizes it, when we have a legitimate reason to do so (in particular to allow us to justify the execution of orders for Services) or for the exercise or defense of legal rights.
You can exercise the above rights by contacting us at the contact details referred to in Article 9 hereof.
In accordance with the regulations in force, your request must be signed and accompanied by a photocopy of an identity document bearing your signature and specify the address to which the response must be sent. We may ask you to provide us with more information to respond to your request.
We will do our best to respond to your request as soon as possible. A response will then be sent to you as soon as possible.

+33 7 66 78 85 37 | booking@TOORERS.com
27 rue de la Cour des Noues
75020 - Paris
SAS with a capital of 20 000€
SIREN XXXXXXX
In the event that we are unable to respond to your requests in a way that satisfies you, you can also file a complaint upon the CNIL.
3 Place de Fontenoy - TSA 80715
75334 PARIS CEDEX 07
Tél : +33 1 53 73 22 22

8. MANAGEMENT OF YOUR SUBSCRIPTION TO NEWSLETTERS AND PROMOTIONAL EMAILS
You can also click at any time on the unsubscribe links in our newsletters and promotional emails.
However, we draw your attention to the fact that even if you unsubscribe from promotional communications, we may continue to send you non-promotional letters, calls and/or emails, such as those relating to the provision of services that you may have subscribed to with TOORERS.

9. TOORERS CONTACT
For any information or questions regarding this Data Management Policy, TOORERS is at your disposal:
- By phone from Monday to Friday, from 9am to 5pm (France time): +33 7 66 78 85 37,
- Mainly by email at: booking@TOORERS.com,
- By post:
TOORERS SAS
27 rue de la Cour des Noues
75020 - Paris
France