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Cookies Policy

This Cookie policy applies to the global organ­iz­a­tion of Sodexo entit­ies (here­in­after referred to as “Don Juan II” or “we”, or “our”) for all dimen­sions and activ­it­ies, in all geograph­ies where we oper­ate. Where local legis­la­tion requires a higher level of protec­tion than this Policy for Personal Data includ­ing data collec­ted via Cook­ies, the local legis­la­tion will always take preced­ence over this Cookie policy.
Sodexo is the data Control­ler who collects and processes the personal inform­a­tion you provide on our differ­ent websites, portals, applic­a­tions, and plat­forms (“Our Site”).
Our Cookie policy aims to show you how we respect the privacy of all visit­ors and users of Our Site. 
If you have any ques­tions regard­ing the more general processing of your personal inform­a­tion on Our Site, please refer to our Online Privacy Policy at [https://donjuan2.yachts­de­paris.fr/en/privacy-policy] or contact us by send­ing an email to the follow­ing email address: dpo.group@s­o­dexo.com.

DEFIN­I­TIONS

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.
In addi­tion, we also use Cook­ies on certain parts of Our Site to commu­nic­ate with third party data providers to extra­pol­ate your digital beha­viour. This helps us under­stand your beha­viour and provide more relev­ant advert­ising in the future.
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? 
When you first visit Our Site, a banner aimed at obtain­ing your consent to the use of Cook­ies will appear. 
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.

When you choose to refuse Cook­ies, an opt-out Cookie will be placed on your device, so that we can record the inform­a­tion that you have objec­ted to the use of Cook­ies. Every six (6) months, we will ask you to confirm your choice to the install­a­tion of Cook­ies with the reappear­ance of the Cookie banner.

If you delete the opt-out Cookie (by eras­ing your browser cache or using the privacy mode for example), it will no longer be possible to identify you as having opted out to the use of Cook­ies. Consequently, you will be offered the choice concern­ing Cook­ies again the next time you visit Our Site.
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.  

► Setting up your device or browser settings to accept or refuse 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.
Please also note that you would need to set up all the browsers of your differ­ent devices (tablets, smart­phones, computers) in order to always refuse Cook­ies. There are vari­ous ways to config­ure browsers. Please refer to the “Help” section of your browser to under­stand how to config­ure it and exer­cise your options. 
•    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
We may change this Cookie policy state­ment as needed. Please note that this policy is likely to change with the future entry into force of any new applic­able regu­la­tion or law, and in partic­u­lar in the European Union, the e-Privacy Regu­la­tion. If changes to the policy are made, it may take up to 30 busi­ness days before new privacy prac­tices are imple­men­ted. Check this page peri­od­ic­ally if you would like to monitor changes. Changes in this policy may also trig­ger the Cookie banner to reappear. 

7. CONTACT US 
If you have any ques­tions or you do not feel that your concerns have been addressed in this Cookie policy, please contact us by send­ing an email to the local data protec­tion team at dpo.group@s­o­dexo.com or submit your data protec­tion related query or concern via the Request webform.
For further inform­a­tion on your data protec­tion rights please refer to the Online privacy policy.
If you have a general enquiry, not related to data protec­tion, please contact contact­s@ydp.fr.

Last version:  11th April 2022