Sodexo is the data Controller who collects and processes the personal information you provide on our different websites, portals, applications, and platforms (“Our Site”).
Controller : The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law
Cookies : As defined in Section 1 of this policy
Our Site : The Don Juan II website, portal, application, or platform you are using
Personal data : Means any information relating to an identified natural person or one that can be directly or indirectly identified by reference to an identification number or to one or more factors specific to this person
Processor : A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
“us” or “our” : The Sodexo entity acting as data Controller
“you” : Our Site user/visitor
1. WHAT ARE COOKIES AND SIMILAR TECHNOLOGIES?
Cookies are small files, downloaded on your device when you access Our Site, with the aim to recognize your device or to store information about your preferences or past actions. They are used to help you navigate efficiently and perform certain functions on all our different Sites.
Other tracking technologies, such as pixel tags or web beacons, may also be used on your device to collect unique identifiers associated with it and other data such as your IP address. Pixels tags or web beacons are small images placed on a web page or in an email. The web beacon operates as a tag that records a user’s visit to a particular web page or viewing of a particular e-mail.
Some tracking technologies are specific to mobile applications such as the SDKs (Software Development Kit). SDKs are packages of tools that help our apps function on an iOS or Android environment. SDKs help us understand how you interact with Our Site and collect certain information about the device and network you use to access, it also helps our applications communicate with third parties through what is called an application programming interface, or API (e.g. when sharing content on Facebook). SDKs may then collect and send data back to the third party that provides them (e.g. Google or Apple, Facebook etc.), which may be used to build your profile as the application user, which can then be used for targeted ads.
These tracking technologies use data in the same way as cookies and as such are subjected to this policy.
We use the term “Cookies” in this document for all the different kinds of tracking technologies, as a facilitator for the global understanding on all Our Sites.
2. WHAT COOKIES DO WE USE?
The types of Cookies that we use may be:
► Session Cookies: such Cookies allow Our Site to link your actions during a session and are automatically deleted when you close your session on Our Site.
► Persistent Cookies: such Cookies remain stored in your device until it reaches a defined expiration date which can be days or minutes. They may be used for a variety of purposes including remembering your preferences and choices when using a Site or for targeted advertising.
► First party Cookies: such Cookies are stored by the Site you are visiting, with the purpose to improve your experience and are set by a Site owner (us).
► Third party Cookies: such Cookies are set by a technology provider, such as an analytics company, advertising network or social media platform that is independent from us.
More specifically, the Cookies used on Our Site are categorized as follows:
► Strictly necessary cookies;
► Functional cookies;
► Audience measurement cookies;
► Targeting cookies (which can also include social network Cookies)
A. STRICTLY NECESSARY COOKIES
Strictly necessary Cookies are Cookies that must be present for the Site to provide the basic functions and without which the Site and its functionalities would not work correctly.
They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms (e.g., to register to events or to provide feedbacks). They can also maintain your session open when you identify yourself on the Site.
Your consent is not necessary for these Cookies according to the applicable regulation but you should be informed of their use.
More information on the different Strictly necessary Cookies used on Our Site, including the data retention period, purpose and third parties if any, can be found in the cookie settings and in Sections 3 and 4 of this policy.
B. FUNCTIONAL COOKIES
Functional Cookies help us to remember the settings which you have selected or assist with other functionality when you use Our Site. This helps us remember your preferences when you return to Our Site.
These Cookies enhance functionality and personalization. They may be set by us or by third party providers whose services we have added to Our Site. You can set your browser or cookie settings to block these Cookies, but be aware that, in that case, some or all of these functionalities may not function properly and that some parts of Our Site may not work.
You can manage your consent and find more information on the different Functional Cookies used on Our Site, including the data retention period, purpose and third parties if any, can be found in the cookie settings and in Sections 3 and 4 of this policy.
C. AUDIENCE MEASUREMENT COOKIES
Audience measurement Cookies, which include analytics technologies, help us with the performance and design of Our Site. This function allows us to measure how many times a page has been visited, to know which pages and functionalities are the most and least popular and see how visitors move around the Site to improve your experience.
Those Cookies might also count visitors who have come to Our Site after having viewed a Sodexo banner ad on a third-party site.
If you do not accept these Cookies, or withdraw your consent, we will have no supporting information to improve Our Site or to determine how well it is received by our end users. These Cookies basically allow you to let us know how well Our Site is doing.
The information collected by these Cookies could also be aggregated. Our Site analytics metrics, reports and statistics, if used alone, do not allow us or our providers, to identify an individual User. In this case, the Cookie may not be subject to your consent.
D. TARGETING COOKIES
Targeting, and or “advertising” Cookies are installed on Our Site by us and our advertising partners to present advertisements that are relevant to you and better reflect your interests instead of generic advertisements that might not interest you. These cookies can include social network Cookies that allow you to share content on social networks and to improve the user-friendliness of our content thanks to the sharing buttons, in particular towards Facebook, Twitter and LinkedIn.
The social networks that provide the sharing buttons may identify you through this process only if your account on the relevant network was activated on your terminal. Sodexo does not have control over the process used by social networks to collect information about you.
Targeting Cookies uniquely identify your browser and/or your device. If you do not allow these Cookies, you will not experience our targeted advertising across different platforms. It is possible however that you may still see our non-targeted advertisements on these platforms.
These Cookies collect information relating to the origin of your visit, where you were exposed to Sodexo advertising, what advertising feature you saw, whether you arrived directly or indirectly to Our Site, the device you used to visit Our Site and which downloads you performed.
You can manage your consent and find more information on the different Targeting Cookies used on Our Site, including the data retention period, purpose and third parties if any, in the cookie settings and in Sections 3 and 4 of this policy.
3. INTERNATIONAL TRANSFERS OF PERSONAL DATA?
Specific information regarding international transfers. The use of some of these Cookies may lead to international transfers of your Personal data to third parties located in third-parties countries that do not offer the same level of protection of Personal data as within the European Union, namely in the United States of America essentially. Formal data processing agreements have been concluded with those third parties, but they are not considered as providing appropriate safeguards by the supervisory authorities, in accordance with article 46 of the GDPR.
Indeed, the risks associated with those international transfers of Personal data are that, since the third parties concerned can be qualified as a provider of electronic communications services, local administrative and governmental authorities might have access to your Personal data in accordance with applicable national surveillance laws.
Nonetheless, according to the GDPR, those kinds of international transfers of Personal data are possible if you explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision or alternative appropriate safeguards.
Therefore, if you consent to audience measurement cookies through the cookies banner or the cookie settings, please be aware that you consent to those transfers, and accept the risks described above.
You can manage your consent to the cookies and to the transfers of Personal data, and find more information on the different Audience measurement Cookies used on Our Site, including the data retention period, purposes and information regarding international transfers of Personal data to third parties if any (type of data transferred, security measures implemented so that the transfers can be carried out in a secure way for the data subjects, recipients), in the description of the cookies in the cookie settings and in Sections 3 and 4 of this policy. If you refuse to consent it will have no consequence on your use of the Site.
4. HOW LONG ARE COOKIES STORED?
Session Cookies are automatically deleted when you close your session.
Persistent Cookies will be stored on your device for a maximum duration of 13 months unless you clear the Cookies using your browser settings and erase your browser cache.
More information on the duration of each Cookie used on Our Site can be found in the cookie settings.
5. HOW TO MANAGE COOKIES ON OUR SITE?
As long as you have not expressed your choice, this banner will remain visible, in accordance with the applicable regulation and no Cookies (other than Strictly Necessary Cookies) will be installed on your device.
Strictly necessary Cookies do not require your consent.
For Functional, Audience measurement and Targeting Cookies, you can give your consent or refuse them at any time by:
► Using the Cookie settings available on the banner or at any time on Our Site;
The Cookie settings provide all the information about the purpose of each Cookie that could be installed on your device in the “Cookie Details”. You can then make an informed choice for each of the categories of Cookies.
However, please be aware that if you do turn off Cookies you will not be able to fully experience some of the features of Our Site. For example, you will not be able to benefit from automatic log-on and other personalization features of Our Site.
• Using Google ChromeTM;
• Using Mozilla Firefox TM;
• Using Microsoft Edge TM;
• Using Opera TM;
• Using Internet Explorer TM;
• Using Apple Safari TM.
You also have the possibility to disable the following audience measurement cookies:
• You can disable “Google Analytics” Cookies, by downloading the module accessible from the following address: https://tools.google.com/dlpage/gaoptout/
• You can disable the Insight Tag of LinkedIn, by modifying your user settings on LinkedIn: https://www.linkedin.com/psettings/
• Contentsquare is a solution which provides us with User behavior analytics in order to enhance User experience.
Regarding social network Cookies, please consult the relevant policies of the social network to learn more about the purposes for which they use the information collected via the sharing buttons and to know how to exercise your choice.
6. CHANGES TO THIS COOKIES POLICY
7. CONTACT US
If you have a general enquiry, not related to data protection, please contact email@example.com.
Last version: 11th April 2022