Last updated: May 2018
I. PERSONAL DATA
In general, you can visit the THE TRAMP Site without disclosing any personal information about you. In any case, you are in no way obliged to transmit this information to THE TRAMP.
However, in case of refusal, you may not be able to benefit from certain information or services that you have requested. As such, THE TRAMP may be required in certain cases to ask you to enter your surname, first name, email address, telephone number, company and function (hereinafter your “Personal Information”). By providing this information, you expressly agree that it will be processed by THE TRAMP for the purposes indicated in point 2 below and for the purposes stated at the end of each form.
In accordance with the General Data Protection Regulation (“General Data Protection Regulation”) adopted by the European Parliament on April 14th, 2016, and the amended Data Protection Act of January 6th, 1978, THE TRAMP informs you of the following points:
- 1. Identity of the controller
The controller is CsetID, with its registered office at 2, chemin de BLANDONNET, 1214 Vernier – SUISSE.
Tel. : +41 (0) 22 301 09 82.
- 2. Purposes of the treatment
THE TRAMP may process your Personal Information:
(a) for the purpose of providing you with the information or services you have requested (in particular: sending the Newsletter, commercial offer, white papers or the assessment of your level of compliance via a quiz); and or
(b) for the purpose of collecting information enabling us to improve our Site, our products and services (in particular by means of cookies); and or
(c) for the purpose of contacting you about various THE TRAMP events, including product updates and customer support.
- 3. Recipients
Only THE TRAMP is the recipient of your Personal Information. These, whether in individual or aggregated form, are never transmitted to a third party, notwithstanding the subcontractors that THE TRAMP uses (you will find more information about them in point 7 below). Neither THE TRAMP, nor any of its subcontractors, sells the personal data of visitors and Users of its Site.
- 4. Shelf life
Your Personal Information is retained by THE TRAMP only for the time corresponding to the purpose of the collection as indicated in 2 above which can not in any case exceed 24 months.
- 5. Computer Rights and Freedoms
You have the following rights regarding your Personal Information, which you can exercise by writing to us at the postal address mentioned in point 1 or by completing this form.
o Right of access and communication of data
You have the faculty to access the Personal Information that concerns you.
However, because of THE TRAMP’s obligation of security and confidentiality in the processing of personal data, you are informed that your request will be processed provided that you provide proof of your identity, including the production a scan of your valid ID (if requested by our dedicated electronic form) or a signed photocopy of your valid ID (in case of written request).
THE TRAMP informs you that it will be entitled, if necessary, to oppose clearly abusive requests (by their number, their repetitive or systematic nature).
To help you in your process, especially if you wish to exercise your right of access by means of a written request to the postal address mentioned in point 1, you will find by clicking on the following link a mail template developed by the National Commission of Computing and Liberties (the “CNIL”).
o Right to rectify data
Under this right, the law allows you to request the rectification, updating, locking or deletion of data concerning you that may be inaccurate, erroneous, incomplete or obsolete.
Also, you can set general and specific guidelines regarding the fate of personal data after your death. In this case, the heirs of a deceased person may demand to consider the death of their loved one and / or to make the necessary updates.
To help you in your process, especially if you wish to exercise, for your own account or on behalf of one of your deceased relatives, your right of rectification through a written request to the postal address mentioned in point 1, you will find by clicking on the following link a mail template developed by the CNIL.
o Right of opposition
The exercise of this right is only possible in one of two situations:
- When the exercise of this right is based on legitimate grounds; or
- When the exercise of this right is intended to prevent the collected data from being used for commercial prospecting purposes.
To help you in your process, especially if you wish to exercise your right of opposition by means of a written request addressed to the postal address indicated in point 1, you will find by clicking on the following link a model of mail elaborated by the CNIL.
- 6. Response time
THE TRAMP undertakes to respond to your request for access, rectification, opposition or any other request for additional information within a reasonable period of time, which may not exceed one month from receipt of your request.
- 7. Authorized service providers and transfer to a third country of the European Union
THE TRAMP informs you that it uses its authorized service providers to facilitate the collection and processing of the data that you have communicated to us. These service providers may be located outside the European Union and have the data collected through the various forms on the Site (except for the form allowing you to exercise your rights Computer and Freedoms which is proposed and operated by THE TRAMP).
THE TRAMP has previously ensured the implementation by its providers of adequate guarantees and compliance with strict conditions of confidentiality, use and data protection. In particular, vigilance was focused on the existence of a legal basis for any transfer of data to a third country. As such, one of our service providers is subject to internal corporate rules (or “”Binding Corporate Rules””) that were approved by the CNIL in 2016 when others obey not only Standard Contractual Clauses but also Privacy Shield.
- 8. Complaint to the competent authority
If you consider that THE TRAMP does not comply with its obligations regarding your Personal Information, you may submit a complaint or request to the competent authority. In France, the competent authority is the CNIL to which you can address a request electronically by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet.
II. POLICY RELATING TO COOKIES
- 1. General information on cookies on the THE TRAMP website
THE TRAMP, as publisher of this website, may proceed to the implementation of a cookie on the hard drive of your terminal (computer, tablet, mobile etc.) to ensure a smooth and optimal navigation on our website.
“Cookies” are small text files that allow us to recognize your computer, tablet or mobile device in order to personalize the services we offer.
The information collected through cookies does not in any way identify you by name. They are used exclusively for our own needs in order to improve the interactivity and the performance of our website and to send you contents adapted to your centers of interests. None of this information is disclosed to third parties except where THE TRAMP has obtained your prior consent or when the disclosure of such information is required by law, by order of a court or any administrative authority or judicial authority to know.
To better inform you about the information that cookies identify, you will find below a table listing the different types of cookies that may be used on the website of THE TRAMP, their name, purpose and their shelf life.
- 2. Setting your preferences on cookies
You can accept or refuse the deposit of cookies at any time
When you first log on to the THE TRAMP website, a banner briefly outlining information about cookies and similar technologies will appear at the bottom of your screen. This banner warns you that by continuing your navigation on the THE TRAMP website (by loading a new page or by clicking on various elements of the site for example), you accept the deposit of cookies on your terminal. You are also deemed to have consented to the deposit of cookies by clicking on the “”X”” icon to the right of the banner at the bottom of your screen.
Depending on the type of cookie involved, collecting your consent to deposit and read cookies on your device may be imperative.
a. Cookies exempt from consent
In accordance with the recommendations of the Commission Nationale Informatique et Libertés (CNIL), some cookies are exempt from the prior collection of your consent to the extent that they are strictly necessary for the operation of the website or have the exclusive purpose of allowing or facilitating electronic communication. These include session ID, authentication, load balancing session cookies as well as cookies for customizing your interface. These cookies are fully subject to this policy to the extent that they are issued and managed by THE TRAMP.
b. Cookies requiring the prior collection of your consent
This requirement applies to third-party cookies that are termed “persistent” as long as they remain in your device until they are deleted or expired.
Because such cookies are issued by third parties, their use and deposit are subject to their own privacy policies, which you will find below. This cookie family includes audience measurement cookies (including Google Analytics), advertising cookies (which THE TRAMP does not use) and social sharing cookies (including Facebook, YouTube, Twitter and LinkedIn ).
Audience measurement cookies provide statistics about the use and use of various elements of the website (such as the content / pages you visited). These data contribute to improving the ergonomics of the THE TRAMP website. An audience measurement tool is used on this website :
Social network sharing cookies are issued and managed by the publisher of the social network concerned. Subject to your consent, these cookies allow you to easily share some of the content published on the THE TRAMP website, including via a “button” application sharing according to the social network concerned. There are four types of social sharing cookies on the THE TRAMP website:
o YouTube, which you will find help to delete cookies from the Google Chrome browser by clicking on the following link: https://support.google.com/youtube/answer/32050?hl=fr but also the policy complete cookie information from the following link: https://www.google.fr/intl/fr/policies/technologies/cookies/
c. You have various tools for setting cookies
Most Internet browsers are configured by default so that cookies are allowed to be posted. Your browser offers you the opportunity to change these standard settings so that all cookies are rejected systematically or that only part of the cookies is accepted or refused according to their issuer.
ATTENTION: We draw your attention to the fact that the refusal of the deposit of cookies on your terminal is nevertheless likely to alter your user experience as well as your access to certain services or functionalities of this website. If applicable, THE TRAMP declines any responsibility for the consequences related to the degradation of your navigation conditions that occur because of your choice to refuse, delete or block cookies necessary for the operation of the site. These consequences can not constitute damage and you can not claim any compensation for this fact.
Your browser also allows you to delete existing cookies on your device or to notify you when new cookies may be placed on your device. These settings do not affect your navigation but you lose all the benefit of the cookie.
Please find below the many tools available to you so that you can set the cookies on your device.
d. The setting of your Internet browser
Each Internet browser has its own cookie management settings. To find out how to change your cookie preferences, please find below the links to the help you need to access your browser’s menu provided for this purpose:
For more information on the tools for controlling cookies, you can consult the website of the CNIL: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.
e. The setting of the tarteaucritron tool
The deactivation of cookies can also be done directly via the tarteaucrone tool set up on the THE TRAMP website. Interactive, it allows you to manage your cookies via a banner available at the bottom right of the page viewed (“”Service Management”” button) and list all active cookies. To deactivate a cookie, simply click on the cross next to the proposed service. If all cookies are deactivated, the banner dedicated to collecting the user’s consent will reappear when the page is refreshed.
For any query or additional request for information on this policy cookies, thank you kindly contact us through our form.