PRIVACY POLICY
1. DATA CONTROLLER
VARIATIONS INTERNATIONAL (SAS, simplified joint-stock company) SIRET: 50965150100041 Address: 78 RUE DE LA FEDERATION 75015 PARIS
Controller contact:
- Name: Catherine TANNEAU
- Email: contact@activision-coaching.com
2. PURPOSES AND LEGAL BASES FOR PROCESSING
2.1 Processing purposes
Navigation: Improve browsing speed and website functionality. Personalization: Adapt content and features to your preferences during your next visits. Statistics: Analyze website usage anonymously to optimize its management and performance. Services: Provide the information, goods, products and services you request. Communication: Send you newsletters and commercial communications related to our services. Orders: Process and manage your purchases of products, services or information. Recruitment: Manage and process job applications and recruitment requests. Compliance: Comply with legal obligations for data retention and protection. Security: Protect your personal data against unauthorized access or misuse. Audience: Measure site traffic by geographic region to ensure global coverage. Behavior: Analyze browsing flows and clicks to better understand site usage.
2.2 Legal basis for processing
Consent of the data subject, Legitimate interest pursued by the data controller
In accordance with Article 6 of the General Data Protection Regulation (GDPR), we process your personal data based on appropriate legal grounds, including: • Consent (for newsletters, non-essential cookies) • Contract performance (for delivery, billing) • Compliance with legal obligations (accounting, declarations) • Legitimate interest (security, service improvement)
3. PERSONAL DATA COLLECTED
We collect and process the following categories of personal data: • First and last name • Email address • Phone number • Company
This data is collected in compliance with the principle of minimization and is strictly necessary for the intended purposes.
4. SOURCES AND COLLECTION METHODS
Your personal data is collected through the following means: • Contact forms • Registration forms • Cookies
During each collection, you are informed of the mandatory or optional nature of the requested data.
5. RETENTION PERIODS
Personal data is retained for the following periods, determined based on legal obligations, processing purposes and the principle of storage limitation:
• Prospects and individuals who have not signed a contract: 3 years • Customers after the end of the contractual relationship: 3 years • Archiving for accounting and tax purposes: 10 years • Browsing data and cookies: 13 months • Marketing data and newsletters: 3 years without interaction
Upon expiration of these periods, data is either permanently deleted or irreversibly anonymized, in accordance with the principle of storage limitation (Article 5.1.e of the GDPR).
Automatic deletion procedures are implemented to ensure compliance with these periods.
6. DATA RECIPIENTS
6.1 Internal recipients
Your data may be shared internally with departments concerned by the processing purpose, in compliance with the need-to-know principle.
6.2 Subprocessors
We use the following subprocessors, carefully selected for their data protection guarantees:
• Neocamino (CRM & forms) - Location: France • Google (Statistical Analysis, online advertising) - Location: United States
Learn more about Google's data usage
All our subprocessors are bound by contracts compliant with Article 28 of the GDPR, guaranteeing the protection of your personal data.
6.3 Other recipients
Your data may be communicated to competent authorities upon legal request and within the framework of procedures provided by law.
7. DATA TRANSFERS OUTSIDE THE EUROPEAN UNION
Some of your data may be transferred to countries located outside the European Union.
Countries concerned: United States
These transfers are governed by appropriate safeguards in accordance with Articles 44 et seq. of the GDPR (standard contractual clauses, adequacy decision, binding corporate rules, etc.).
8. SECURITY MEASURES
We implement appropriate technical and organizational measures to ensure a level of security adapted to the risk, including:
• Pseudonymization and encryption of personal data • Means to guarantee confidentiality, integrity, availability and resilience of systems • Means to restore data availability in case of incident • Procedure to regularly test and evaluate the effectiveness of measures
Our employees are made aware of data protection and subject to a confidentiality obligation.
9. YOUR RIGHTS
In accordance with the GDPR, you have the following rights regarding your personal data:
• Right of access (Article 15 GDPR): obtain confirmation that data concerning you is being processed and receive a copy
• Right of rectification (Article 16 GDPR): have inaccurate or incomplete data concerning you corrected
• Right to erasure / "right to be forgotten" (Article 17 GDPR): obtain erasure of your data in certain cases
• Right to restriction of processing (Article 18 GDPR): obtain temporary freezing of processing in certain cases
• Right to data portability (Article 20 GDPR): receive your data in a structured format and transmit it to another controller
• Right to object (Article 21 GDPR): object to the processing of your data, particularly for prospecting purposes
• Right to withdraw your consent at any time (if processing is based on consent)
• Right to define directives regarding the fate of your data after your death
9.1 How to exercise your rights
To exercise your rights, you can contact us:
- By email: contact@activision-coaching.com
- By mail: 78 RUE DE LA FEDERATION 75015 PARIS
Response time: Maximum 1 month from receipt of your request. This period may be extended by two months in case of complexity.
Proof of identity may be requested in case of reasonable doubt about your identity.
9.2 Right to lodge a complaint
If you believe that the processing of your personal data constitutes a violation of regulations, you have the right to lodge a complaint with the supervisory authority:
Commission Nationale de l'Informatique et des Libertés (CNIL) 3 Place de Fontenoy - TSA 80715 75334 PARIS CEDEX 07 Phone: 01 53 73 22 22 Website: www.cnil.fr
10. COOKIES AND TRACKERS
We use Cookie Notice to collect and manage your consent regarding cookies and trackers.
Cookies are small files placed on your device when you visit our site. They allow us to: • Ensure proper functioning of the site • Improve your browsing experience • Establish visit statistics • Offer you adapted content
You can modify your cookie preferences at any time via our consent banner or your browser settings.
11. AUTOMATED DECISION-MAKING AND PROFILING
We do not engage in any entirely automated decision-making that produces legal effects concerning you or significantly affects you.
12. DATA BREACH
In case of a personal data breach likely to result in a high risk to your rights and freedoms, we commit to: • Notify the incident to CNIL within 72 hours • Inform you as soon as possible if the risk is high • Take all necessary measures to limit the consequences
13. MODIFICATIONS TO THIS POLICY
This privacy policy may be modified at any time to reflect changes in our practices or regulations.
Last update date: July 9, 2025
We encourage you to regularly consult this page. In case of substantial modification, we will inform you by email or via a notification on our site.
14. CONTACT
For any question regarding this privacy policy or the processing of your personal data, you can contact us:
VARIATIONS INTERNATIONAL Email: contact@activision-coaching.com Address: 78 RUE DE LA FEDERATION 75015 PARIS