Your privacy is important to us and we pay special attention to it. This personal data protection policy (hereinafter the “data protection policy”) describes the information that we collect about you by means of or through the intermediary, in whole or in part, of our website or one of our pages on social networks, but also more generally in the context of your relations with us, and how we treat them (see information relating to the methods of collection, processing and use of your personal data staff).
This data protection policy also specifies the rights you have over your personal data in application of the applicable legal and regulatory provisions.
If you have any questions, comments or concerns regarding this policy, you can of course send them to us at the contact details given below in the paragraph "What are your rights and how can you exercise them?" ".
In addition to the terms defined elsewhere in this policy, the following terms, the first letter of which is capitalized, whether used in the singular or plural in said policy, will have the following definition:
1.1 “Recipient”: refers to the natural or legal person, public authority, service or any other body that receives communication of Personal Data, whether or not it is a third party.
1.2 "Personal data": refers to any information relating to an identified or identifiable natural person (hereinafter referred to as "Data subject"); is deemed to be an "identifiable natural person" a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to its physical, physiological, genetic, psychological, economic, cultural or social identity.
1.3 “Data Controller”: refers to the natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of the Processing.
1.4 “Processor”: refers to the natural or legal person, public authority, department or other body which processes Personal Data on behalf of the Data Controller.
1.5 "Processing": designates any operation or set of operations carried out or not using automated processes and applied to data or sets of Personal Data, such as the collection, recording, organization , the structuring, the conservation, the adaptation or the modification, the extraction, the consultation, the use, the communication by transmission, the diffusion or any other form of making available, the reconciliation or the interconnection, the limitation , erasure or destruction.
2. Who are we and what is our role in the Processing of Personal Data?
2.1 Lord Services (also referred to as “the company” or “us” in this policy) is a public limited company with a board of directors with a capital of € 37,000, registered in the Montpellier Trade and Companies Register under number 889 272 639, whose head office is located 455 Avenue du Professeur Etienne Antonelli (at Subway) - 34070 Montpellier, intra-community VAT number FR60 889 272 639, SIRET 889 272 639 00010, tel: +33 (0) 4 83 43 29 44 , email address: email@example.com .
Its main activity is the development and management of all systems, software, technical solutions, websites, platforms and applications, as well as the acquisition, subscription, holding, management and disposal, in any form, from all parts. social security and all securities in all companies or legal entities. In this context, it also operates as a digital asset service provider (PSAN).
To find out more about our company, Click here .
2.2 The company operates the website accessible to the public at the following url address (hereinafter the "Site"): www.lordtoken.fr . This Site aims to:
- provide users with information enabling them to discover the activity and services offered by the company, as well as its news (events, publications, etc.);
- offer functionalities and / or information allowing users to contact the company and present the services offered by the company, the projects carried out by the latter and to come, or the team working on these projects;
- provide users with an online account and access to a digital asset exchange platform and various associated services as detailed in our general conditions ;
- carry out one-off fundraising operations, in particular by issuing bonds convertible into shares (“OCA”) to be subscribed in cash as part of a bond loan by public offering.
The company also manages pages presenting its activity and allowing it to publish content on social networks and to interact with Internet users (in particular on Facebook, Instagram, Twitter, YouTube, Pinterest or even LinkedIn).
During your navigation and your interactions on the Site, on the pages administered by the company on social networks or, in general during your interactions or exchanges with the company, the latter may be required to collect and process Data. of a personal nature concerning you, for the management of the activities it carries out and for its own account, as Data Controller, whether you are a customer, prospect, contact, Internet user, candidate, supplier, service provider or partner, potential or current (also referred to as “you” or “the affected person (s)” or “the user (s)” in this policy).
In this context, the company applies the principles defined by the legal and regulatory provisions on the protection of personal data, in particular in Regulation (EU) 2016/679 of April 27, 2016 on the protection of natural persons at 'with regard to the Processing of Personal Data ("RGPD") or even Law 78-17 of 6 January 1978 relating to computers, files and freedoms (known as the "Data Protection Act") and its decrees. application.
3. What are the methods of collecting your Personal Data?
3.1 Your Personal Data is collected directly from you, or indirectly from third parties.
3.1.1. In fact, your Personal Data are collected or processed in whole or in part during your browsing on the Site, your interactions with the Site, and when you enter information in the collection forms. of data that may appear there, but also more generally in the context of requests that you may have to send to the company by any means at your convenience, your relationship and your exchanges with the company, as well as when you share content of the Site by means of sharing "buttons" on social networks that may be offered on our Site, or when you browse one of the company's pages on social networks.
In general, your Personal Data is therefore collected directly from you in the aforementioned cases.
3.1.2. However, your Personal Data may also be collected through third parties (cf. indirect collection from third parties).
Indeed, the Personal Data that we collect and process concerning you may possibly be collected or enriched by us, in particular for the purposes of carrying out commercial operations, communication, solicitation, prospecting or marketing, by means of other sources of information (social networks, so-called “public” information, websites, file rentals, etc.).
Likewise, your Personal Data may be transmitted to us by other staff members / contacts within your company or even through third parties in certain situations.
In addition, as regards more particularly Personal Data processed as part of our recruitment operations (for a job or for an internship), we use the information you provide us (eg: form completed for this purpose or more generally information mentioned in your CV) which we include in our file of candidates (CV database). However, we may also be required to approach third parties (for example, recruitment agencies, previous employers, internship supervisors or clients with whom you have worked in the context of previous assignments) or to use other sources of information. (in particular professional social networks, recruitment firms or sites specializing in recruitment) in order to collect information about you with a view to studying your application or your professional profile. In addition, and even in the absence of an application from you, we may be required, in particular as part of our monitoring operations and active search for professional profiles that may correspond to our vacancies to be filled, to collect information. Personal data from third parties (for example, recruitment agencies or "headhunters") or to use other sources of information (in particular professional social networks or sites specializing in recruitment) in order to collect information about you in order to suggest that you apply for one of our job offers.
3.2 In addition, in general, you are informed that in principle:
- if the Processing of your Personal Data is necessary for compliance with our legal or regulatory obligations, the collection of such Data is mandatory;
- if the Processing of your Personal Data is subject to your consent, the communication to our attention of said Data is completely optional (it being specified that their absence of communication could however have the consequence of preventing us at least in certain cases from implementing the Processing concerned);
- if the Processing of your Personal Data is necessary for the performance of a contract or pre-contractual measures taken at your request, the communication of said Data is necessary for the pursuit of this purpose and the company could, in the absence of communication of this Data, to be prevented from fulfilling its contractual obligations or the aforementioned pre-contractual measures;
- if the Processing of your Personal Data is based on the pursuit of our legitimate interests, the communication of said Data is necessary for the pursuit of this purpose, and the absence of communication of your Data could not allow us to implement the Processing concerned or obstruct it. For example, in the absence of providing the information that would be necessary to respond to a request from you (request for information, etc.), your request related to this collection of Personal Data may not be able to be processed or its delayed processing.
Special case: if forms for the collection of Personal Data (for example, forms integrated on the Site or within our pages on social networks, or any collection form in any format whatsoever that we may be required to to make available to you to collect information about you) involve the entry of Personal Data required for the implementation of the associated Processing, the fields concerned will include an asterisk and you will be informed of the possible consequences of a failure to communicate of this information. In the absence of an asterisk, the information requested is optional. In the absence of a specific form, the mandatory data for the purposes pursued will be indicated to you, it being specified that the data not indicated as mandatory are of course optional.
3.3 Apart from specific legal obligations, or otherwise specified in this policy, we do not collect “specific” Personal Data, that is to say which would reveal racial or ethnic origin, political opinions, convictions. religious or philosophical or trade union membership, genetic or biometric data for the purpose of uniquely identifying a natural person, health data or data concerning the sex life or sexual orientation of a natural person .
3.4 Personal data of minors or protected adults: we only offer our services to adults with legal capacity. Also, in general, the use of the Site and the company's dedicated pages on social networks is reserved for adults with legal capacity, the company cannot under any circumstances be held responsible for the use of the Site. or its pages on social networks by minors or incompetent persons, and therefore the consequences that may result therefrom, in particular with regard to the Processing of their Personal Data.
As an exception, we may be required to process Personal Data of minors of at least fifteen years of age when they come into contact with the company with a view to applying for a job or internship offer.
4. What Data is collected, for what Processing purposes, on what grounds and for what durations?
5. Who are the Recipients of your Personal Data? How do we share your Data?
5.1 We ensure that only authorized persons within the company can access your Personal Data when this access is, depending on the purposes pursued, necessary for the exercise of their functions and / or missions, namely in particular :
- authorized personnel (including employees, interns, temporary workers, etc.) of the company, in particular in charge of marketing and communication, sales, recruitment and human resources, customer and prospect relations, administrative, financial and legal aspects , development, IT, projects, ...
5.2 External Recipients are also likely to receive communication of your Personal Data, namely:
- the staff of the departments responsible for controlling our company (statutory auditor, departments responsible for internal or external control procedures, bodies authorized to carry out controls, etc.);
- the staff of our councils (legal, financial, etc.);
- the staff of our partners, including in particular our service providers and suppliers, who are subject to a contract specifying their obligations;
- the staff of our partners, contractual or commercial, and of third-party companies, including in particular the publishers of social networks, the publishers of third-party websites or the publishers of cookies used on our Site, for example for carrying out operations prospecting, communication, etc. or as part of the management of our digital marketing, or even for the operation of our Site in the broad sense (eg: provision and proper functioning of the functionalities offered therein, performance, security, etc.). In this regard, it is also specified as a reminder that if you post content disclosing your Personal Data on the internet, and in particular on our Site or on the pages of the company's social networks, this content may of course be accessible to anyone. Internet user;
- the staff of technical service providers or others involved in activities or assignments for which access to Personal Data is strictly necessary and / or justified. This category of recipients may also include any application, computer program or tool publisher or any payment or verification service provider (in particular identity) that would be used in the context of our activities. or for the purpose of providing you with the services accessible through the Site, or any IT or maintenance provider of the applications, computer programs and / or tools that we use and in which your Personal Data may be processed staff ;
- the customers (potentially including their staff) of the company for certain Personal Data;
- the staff of social and tax bodies authorized to receive, in certain cases, Personal Data;
- the staff of organizations, court officials and ministerial officers, intervening in particular in the context of their debt collection mission;
- where applicable, the staff of the body in charge of managing the list of opposition to canvassing;
- court officers, ministerial officers and, where applicable, the staff of the courts or competent authorities to enable the sale or transfer of all or part of our activities or assets, or in the context of the management and monitoring of pre-litigation and / or litigation;
- our insurers and / or insurance brokers (including their staff).
5.3 Certain partners or third parties (including their staff) are also Recipients of your Personal Data when you use the services accessible through the Site, namely:
- Binance, a third party and independent from Lord Services, which develops, provides, maintains, updates, operates and administers the Exchange Platform ( powered by Binance ) -cf. digital asset exchange platform - accessible from the Site, it being specified that in the context of the use of this platform, the users of said platform (it being specified that they can be a user of the Site or a third party to the Site) be Recipients of some of your Personal Data;
- Banxa, a third-party entity independent of Lord Services, which offers users a service accessible from the Site allowing them to carry out certain transactions on digital assets.
In this regard, it is specified that Lord Services is not responsible for the Processing of Personal Data that could be implemented by these partners and third parties (or by any Recipient whatsoever), the latter implementing their own Respective Personal Data Processing, for which they are respectively sole Processing Managers, Lord Services having no power to determine such Processing or control over such Processing. For information, the user is invited to consult the personal data protection policies of these entities and other documentation that could be made available by said entities with regard to the Processing of Personal Data that they put in place. work, and in particular:
5.4 In addition, given the nature of the services offered and / or accessible through our Site, your Personal Data may naturally be communicated, stored, recorded within the various blockchains used for management, the monitoring and processing of transactions on digital assets that you carry out, because they are necessary for the operation of said blockchains, it being recalled that Lord Services does not manage or control said blockchains, and therefore has no power of determination or control over the Processing of Personal Data that may be implemented within the framework of said blockchains, and that such Processing is in no way the responsibility of Lord Services.
5.5 We may also be required to communicate your Personal Data in the event of legitimate requests from public or authorized authorities, in particular to meet requirements in terms of compliance with the law on Personal Data, national security, against fraud, money laundering and terrorist financing or more broadly the application of legal or regulatory provisions. Your Personal Data may therefore in particular be communicated to any authority empowered to know it, in particular in the event of a requisition from judicial, police or administrative authorities. In these cases, we will study the applicable provisions, the nature of the request, as well as its legitimacy and the proportionality of the information requested. Finally, we reserve the right to report to public authorities activities that we consider in good faith to be illegal and suspected abuses.
5.6 It is specified that the Recipients referred to above are not necessarily or necessarily Recipients of all of your Personal Data, but only of those necessary for the purpose involving such communication.
6. What are your rights and how can you exercise them?
6.1 You benefit, under the terms and conditions and within the limits defined by the legal and regulatory provisions on the protection of Personal Data, the following rights with regard to your Data:
- Right of access: you can obtain confirmation whether or not Personal Data concerning you is processed by the company and, when they are, access to said Personal Data, as well as certain information relating to the Processing of your Personal Data and the characteristics of such Processing;
- Right of rectification: you can request the correction of your Personal Data that you consider incomplete or inaccurate;
- Right to erasure: you can, in certain cases, request the erasure of your Personal Data (except for example if they are necessary for the execution of your contractual relations with the company where applicable, or if they are are necessary for the company to comply with its legal or regulatory obligations or to ascertain or exercise its rights);
- Right to limitation of Processing: you can request limitation of Processing of your Personal Data, allowing you to request in certain cases the marking of your Personal Data in order to limit future Processing;
- Right to the portability of your Personal Data: you have the right in certain cases and under certain conditions to request to receive the Personal Data concerning you that you have provided to us or, when technically possible, to they are transferred to a third party, in a machine-readable form (it being specified that this right to data portability only applies to Processing based on the consent of the Persons concerned or on the execution of contractual relations, and this provided that the Data Processing is carried out using automated processes);
- Right to withdraw your consent: you can withdraw your consent if the Processing is carried out on the basis of your consent, without the withdrawal of such consent prejudicing the lawfulness of the Processing based on the consent made before the withdrawal of it;
- Right to define guidelines for the retention, erasure or communication of your Personal Data after your death. In this regard, in the event of death which would be brought to our attention, please be aware that your Personal Data will in principle be deleted (unless it is necessary to keep it for a specified period for reasons relating to our legal and regulatory obligations and / or the deadlines. statutory prescription and / or mandatory retention referred to above in paragraph 4 in detail of the characteristics of the processing operations), after having been communicated to a third party possibly designated by you.
|Moreover, you get in certain circumstances and under certain conditions laid down by the applicable provisions, a right of objection by which you can object to the processing of your personal data for purposes related to your particular situation, that '' being specified that as regards prospecting operations, including profiling operations which would be linked to such prospecting, you have an absolute right of opposition, which can be exercised at any time, without having to provide a reason or justification.|
Please note : the exercise of these rights is nevertheless limited, with regard to Personal Data which would be necessary for the operation of said blockchains (cf. in particular the Data kept / stored within the blockchains used in the context of management, monitoring and the processing of digital asset transactions). Indeed, this Data necessary for the operation of the blockchains cannot be modified or erased during the life of the blockchain concerned. In addition, the conservation / storage of this Data in said blockchains is not the responsibility of Lord Services, which does not manage or control said blockchains, and which therefore has no power of determination or control over the Processing. Personal Data that may be implemented within the framework of said blockchains, nor to pass on the exercise by the Data Subjects of their rights to said blockchains.
6.2 Regarding the Processing of your Personal Data implemented by the company, these rights are exercised i) by email to the following email address: firstname.lastname@example.org or ii) by post to the address next: 455 Avenue du Professeur Etienne Antonelli - 34070 Montpellier (at Subway). In any event, in the event of reasonable doubt as to the identity of the person submitting such a request to exercise their rights, the company may always request that it be provided with additional information necessary to confirm the identity of the Person concerned. and request for this purpose, when the situation so requires, a photocopy of an identity document bearing the signature of the holder. In such a case, the aforementioned response times will be suspended pending receipt of the additional information necessary to identify the Data Subject.
If such a request is received, it will be answered as soon as possible and in any event within a maximum period of one month from receipt of the request. If necessary, this period may be extended by two months, taking into account the complexity and the number of requests received, in which case the applicant will be informed.
The request may be presented by the Data Subject or by a person specially authorized for this purpose by the Data Subject, provided that this authorized person can prove his identity and the identity of the principal, his mandate as well as the duration and of the precise object thereof. The mandate must also specify whether the representative can be made the recipient of the response.
6.3 In addition and for the record, in certain cases we may be considered as jointly responsible for the Processing of your Personal Data with the social networks within which we have dedicated pages or with which we offer you interactions (see details). of the above purposes). Depending on the social network concerned, our joint data controllers can be:
- with regard to Facebook and Instagram: Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbor Dublin 2, Ireland. For more information on how Facebook processes your Personal Data when you use the Facebook or Instagram social network, we invite you to refer to the Data Use Policy of Facebook Ireland Limited as well as the Policy use of Instagram data , but also the Facebook and Instagram "cookies" policy, where applicable, in order to configure the cookies used on the pages of these social networks;
In these cases, you can also, for the exercise of your aforementioned rights, consult your account settings on the aforementioned social networks and contact you:
- with regard to Facebook and Instagram: to the Data Protection Officer of Facebook Ireland Limited by email, in particular using the dedicated contact form ;
- with regard to Twitter: to the Data Protection Officer of Twitter by email, in particular using thededicated contact form ;
- with regard to Linkedin: to the Data Protection Officer of LinkedIn by email, in particular using the dedicated contact form ;
- with regard to YouTube: to the Data Protection Officer of Google Ireland Limited by email, in particular using the dedicated contact form ;
- in the case of Pinterest: to the Pinterest Europe Ltd help center using the dedicated contact form .
6.4 You also have in any event the right to lodge a complaint with the competent supervisory authority (in France, this is the National Commission for Computing and Liberties known as “Cnil”: 3 place de Fontenoy - TSA 80715 - 75334 Paris cedex 07; tel.: 01 53 73 22 22) if you believe that the Processing of your Personal Data is not carried out in accordance with the legal and regulatory provisions on Data protection of a personal nature.
To understand your rights, you can also refer to the explanations provided by the Cnil here:https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles
6.5 We point out that in application of articles L.223-1 et seq. Of the Consumer Code, you can, if you are a consumer, object at any time to being canvassed by telephone, by registering for free on the site. “ Www.bloctel.gouv.fr ” .
7. How secure is your Personal Data?
7.1 The company implements appropriate organizational and technical security measures, particularly with regard to the categories of Personal Data processed, the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the Processing as well as the risks, the degree of probability and severity of which vary, for the rights and freedoms of individuals, to protect your Personal Data against any malicious intrusion, any loss, alteration or disclosure to third parties. unauthorized third parties, and more generally to preserve the security and confidentiality of said Personal Data and guarantee a level of security adapted to the risk.
Due to the difficulties inherent in carrying out an activity on the internet and the risks, which you know, resulting from the transmission of data by electronic means, the company can not however be held to an obligation of result.
If difficulties arise, the company will make its best efforts to limit the risks and take all appropriate measures, in accordance with its legal and regulatory obligations (corrective actions, informing the CNIL and, where applicable, the persons concerned, etc.).
7.2 When developing, designing, selecting and using our services offered on the Site which are based on the Processing of Personal Data, the company takes into account the right to data protection at personal character by default and from their design (cf. so-called “Privacy by design and by default” principles).
7.3 Access to Personal Data concerning you is limited to our employees or partners, and more generally to the Recipients referred to above , who are authorized and who need to know them in the context of the performance of their missions and / or of their activities.
7.4 In the event of subcontracting of part or all of the Processing of Personal Data, the company contractually imposes on its Subcontractors guarantees of security and in particular of confidentiality with regard to Personal Data. to which they may have access (appropriate technical and organizational measures to protect this Data).
8. Are your Personal Data transferred outside the European Union?
8.1 Your Personal Data is preferentially processed in the European Union.
8.2 In the context of the aforementioned purposes, some of your Personal Data may however be transferred to third-party entities established in countries located outside the European Union (eg: Sub-contractors of the company involved in the Processing aforementioned,…).
Some of these entities Recipients of your Personal Data are considered to ensure a sufficient level of protection of Personal Data because they are established in a country whose regulations on the protection of Personal Data have been recognized. as ensuring an adequate level of protection of said Data (see adequacy decisions of the European Commission https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/ adequacy-decisions_en ).
In addition, if the country of the entity Recipient of your Personal Data does not offer an adequate level of protection of said Data, we ensure that the appropriate security and confidentiality measures are taken to ensure the maintenance of the protection of your Data.
Also, in these cases, you are informed that the transfers of your Personal Data to other entities outside the European Union are governed by the conclusion, with the Recipients of this Data, of contractual clauses in accordance with the recommendations of the European Commission to ensure that the appropriate guarantees are taken regarding the protection of said Data.
We also point out that transfers of Personal Data outside the European Union are lawful if the transfer is necessary for the performance of a contract between the Data Subject and the Data Controller or for the implementation of pre-contractual measures taken at the request of the Data Subject, if the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the Data Subject between the Data Controller and another natural or legal person, or if the Data Subject has given his / her explicit consent to the proposed transfer, after having been informed of the risks that this transfer could entail for him / her due to the absence of an adequacy decision and of appropriate guarantees.
A copy of the reference documents referred to in this paragraph can be obtained (free of any commercial information considered sensitive or confidential or covered by trade secrets), from the contact mentioned in the paragraph above "What are your rights and how exercise them? ".
9. What are the links of our Site with third party sites?
9.1 We point out that our digital media (in particular our Site or our pages on social networks) may provide or include links to third party sites, including social network sites. We have no control over the activity of these sites and the policies they apply to protect your Personal Data and your rights, and we cannot control them. We invite you to examine the guarantees offered by these sites, before any interaction with them. In this regard, your attention is drawn to the fact that the personal data protection policy of these sites may be different from that of the company and that it is your responsibility to take cognizance of it.
9.2 If you post content disclosing your Personal Data on the internet, and in particular on social networks, including the pages of the company's social networks, this content may be accessible to any Internet user, and collected or used by third parties. , for purposes which are not our responsibility. In any event, the company's liability cannot be sought in the event that the Processing of Personal Data implemented via one of these third-party sites contravenes the applicable legal and regulatory provisions.
10. Can this data protection policy be modified?
10.1 This data protection policy may be subject to modifications at any time, which will take effect on the date of publication of the corresponding update.
10.2 Indeed, in the event of modification, the new data protection policy will be posted on the Site in the dedicated section. In addition, all forms for the collection of Personal Data which may appear on our Site offer a link to this policy.
10.3 We therefore invite you to consult it regularly.
11. What is the Site's policy on managing cookies?
11.1 Cookies and other tracers or similar technologies may be installed and / or read in your browser or terminal during your visit to the Site.
11.2 Click here to access our "cookie management policy", which is also accessible by an integrated link at the footer (cf. footer) of all the pages of the Site.
Date of last update : 10/09/2021