Policy updated on 08/05/2023

You will find here the privacy policy for ChristianVerny.com (“Site”) and related websites, which are operated by CVY Consulting Ltd (“Company”, “we” or “us” below).

To ensure the data confidentiality, in application of the provisions of Regulation EU 2016/679 of April 27, 2016 and Law No. 78-17 of January 6, 1978 relating to data, files and freedoms, modified on June 20th, 2018, the Company take commitments regarding the protection of personal data.

1. Contact

For any concerns you can send us an email to our support team at  CVYcontact@gmail.com (“Support Team”). 

2. Policy Purpose  

The purpose of this data protection policy is to inform you about the commitments and practical measures taken by the Company to ensure the respect of your personal data.

This policy explains how we collect and use personal information. For any concerns about this policy you can send us an email at Support Team.

3. Acceptance of Privacy Policy  

By the registration and usage of this Site, offers, services, you signify your acceptance of this Privacy Policy and you consent to our use and disclosure of your personal information in accordance with this Policy. 

This Privacy Policy is subject to the Terms of Use published on the Site. If you don’t agree (in whole or part) with the terms of this Policy, you should not use this Site and should cancel your registration, by logging into your account or ask to Support Team to cancel it.

4. Must be over 18 years old

The Company or Network Sites are intended for person over 18 years old. If we discover a person who registered on the Site is under the age of 18, we will delete profile and all rights associated.

5. Policy change

We get your attention to the fact that we may have to make changes to this policy, in whole or part, to comply with any new regulations, case law, editorial, technical or to adapt to our business practices. 

When we make changes, we will update our Privacy Policy updated thirty (30) days before it comes into effect to ensure that you are aware of these changes (thru Site or email). Your continued use of our Site and services constitutes your consent to the revised Privacy Policy. If you don’t agree with the new terms of the Privacy Policy, in whole or part, you must terminate your registration by unsubscribing at Support Team and cease to use the Site.

6. Site editor

The Site is edited by the Company, incorporated in the registrar of Companies of England and Wales under the number 10996158 with registered office in Ingles Manor - Castle Hill Avenue à Folkestone (CT20 2RD) (United Kingdom).

The Company is represented by Christian Verny as Director.

The publication director of the Site is Christian Verny.

The Site is hosted by Infomaniak Network SA, Rue Eugène-Marziano 25, 1227 Genève (Switzerland). Phone: +41 22 820 35 40.

7. Responsible for treatment  

The information are subjects of a computer processing of which the person in charge is the Company, represented by Christian VERNY as director.

8. Collection and use of personal data

The Company only collects and processes data strictly necessary for the purpose for which it is processed. 

What data are collected?

• User data: refers to the data that the User provides, when creating an account by completing the registration form, when requesting a quote or underwriting service. These data include the user's name, date of birth, address, telephone number and email address.

• Transaction data: refers to the data that the User provides when he subscribes to an online service, such as information relating to his method of payment. The collected bank data is transmitted to third parties who help to process and satisfy the requests of the User.  

• Navigation Data: refers to the data collected during the User's navigation on the Site, such as the date, the time of the connection and / or navigation, the type of browser, the browser language, which web pages were visited on the Site, a unique mobile identifier, the IP (Internet Protocol) address, ISP (Internet Service Provider) and other anonymous Site usage data.

9. Purposes of collecting data  

The treatments implemented by the Company have an explicit, legitimate and determined purpose. 

Your data are used mainly for the following purposes: 

• The management of your registration on the Site
• Access to your account
• Enter into a service provision agreement, if applicable
• The management of the subscription to the services of the Company and their follow-up
• Navigation on the Site
• Receipt of commercial and promotional offers from the Company
• The proposal of offers adapted to the interests of the User as they result from his navigation, provided that the user has validated the banner when connecting to the Site
• Billing management for online subscribed services

When collecting data, the user will be informed if certain data must be mandatory or if they are optional.  

The data identified by an asterisk in the registration form are mandatory. Otherwise, access to the services and their use by the user may be restricted. 

10. Legal basis

The legal basis for collecting and using the user's data depends on the data concerned and the specific context in which the Company has collected these data. 

The Company collects user data when:

• The User has given his consent
• The data is necessary to execute a contract concluded with the User (for example to offer access to the Site)
• When the processing meets the legitimate interests of the Company

11. User information

In accordance with the regulations on personal data, the Company informs you about the processing of personal data that is implemented. 

Thus, the Company informs you of: 

• The identity and contact information of the controller 
  
• The purposes of the processing for which the personal data are intended and the legal basis of the processing
• Where applicable, the legitimate interests pursued by the Company
• The recipients of the personal data
• Where applicable, the fact that the Company is transferring personal data to a country outside the European Union
• The retention period of the personal data or the criteria used to determine this duration
• The existence of the right to ask the Company for access to personal data, rectification or deletion thereof, a limitation of treatment, the right to oppose the processing, the right to the portability of data and the ability to define the fate of his data after his death
• The existence of the right to withdraw consent at any time, without prejudice to the lawfulness of consent-based treatment prior to withdrawal
• The right to lodge a complaint with a supervisory authority
• Information on whether the requirement to provide personal data is of a regulatory or contractual nature or whether it is a condition for the conclusion of a contract and whether the data subject is required to provide the personal data, as well as the possible consequences of the non-provision of these data
• The existence of automated decision making, including profiling, information useful for understanding the algorithm and its logic

12. Data recipients  

The Company undertakes to take all appropriate precautions, organizational and technical measures to preserve the security, integrity and confidentiality of the data and in particular to prevent them from being distorted, damaged or unauthorized third parties having access to them. 

The Company only communicates your personal data to authorized and determined recipients, for example: 

• His staff
• Its subcontractors to provide support and set up services in connection with the use of the Site
• Its partners if you have consented to this communication

The data may be transferred to countries outside the European Union that benefit from a European Commission adequacy decision or to the United States by complying with the rules of the Privacy Shield auto-certification mechanism for companies established in the United States that has been recognized by the European Commission as providing an adequate level of protection for personal data transferred by a European entity to companies established in the United States.

In the case your data are transferred outside the European Union, the responsible for treatment guarantees that the transfer is governed by the standard contractual clauses of the European Commission or by internal corporate rules (Binding Corporate Rules) or contractual clauses with a sufficient level of protection of privacy and the fundamental rights of individuals.

You are informed that your personal data are accessible by one of our service providers located in the United Kingdom or France for the provision of IT services.

13. Data retention

The Company keeps your data only for the period necessary for the purposes for which they were collected and in compliance with the legislation in force.

Your data used for commercial prospecting purposes is retained for a maximum of 3 years from the last contact with the responsible for treatment.

14. Security

The Company ensures the security of your personal data by implementing data protection enhanced using physical and logical security and takes the necessary technical and organizational measures in this respect.

Our security measures include appropriate access control, encryption (if applicable), and regular security assessments.

15. Your rights

In application of the regulations on personal data, you have the right to access, rectify, erase, limit processing, portability and define the fate of your data after your death relative to the all data concerning you which is exercised with the Company by email at Support Team.

You also have the right to complain with the Information Commissioner’s Office (ICO), a supervisory authority for data protection issues (in the UK: www.ico.org.uk) if you consider that the processing of personal data concerning you constitutes a violation of the regulation on personal data. In such case we will be grateful if you can contact us first, so we can resolve it with you.

16. Cookies

The user is informed that during his visits to the Site, a cookie may be automatically installed on his browser.

What is a cookie?

When consulting the Site or after opening emails sent by the Company and / or its partners, information about your browsing can be saved in so-called "cookies" files installed on your device, subject to the choices that you would have expressed about cookies and that you can change at any time.

A Cookie is a small text file saved in a dedicated area of the hard drive of your device, during the consultation of an online service with your browser software. It allows its issuer to identify the terminal in which it is registered, during the period of validity or registration of the Cookie.

The Cookies emitted on the Site or after the opening of emails are used for the purposes described above, during the period of validity of the concerned Cookie, subject to your choices which result from the parameters of your navigation software used during your visit the Site and whose settings you can change at any time.

Cookies from Company partners (third-party cookies) may be placed on your computer.

Only the issuer of a Cookie may read or modify information contained therein. Different types of cookies are used by the Company and its partners, they have different purposes.

Different types of cookies

We find:

• Cookies strictly necessary
• Analytical Cookies
• Functional Cookies
• Cookies and plug-in of social networks (social buttons)
• Cookies related to targeted advertising operations

Third-party cookies allow the partners of the Company, during the period of validity of these cookies, to:

• Collect navigation information about the terminals consulting the Site
• Determine the advertising contents that may correspond to the centers of interest deduced from the previous navigation of the terminal concerned
• Allow statistics, targeting and re-targeting, as well as customizations of advertising messages

The partners of the Company may, in case of express prior authorization from you, associate the personal data that we transmit to the Cookies deposited on your browser, and are likely to access new data such as your IP address , your type or version of browser or operating system.

Our partners use this information to address or enable the distribution of targeted advertising, perform analysis, measurement and performance reporting for marketing purposes and via different channels or platforms. For example, our partners may send you an advertisement on your browser based on your browsing or your consumption habits.

Your rights

You may, at any time, withdraw your consent and terminate the targeting by refusing Cookies in your browser or through the preference managers of the ads offered by the partners or in the unsubscribe links present in the emails.

It is the responsibility of each Cookies issuer to fulfil your wish to exercise your rights, including the right to withdraw your consent to deposit tracers on your device.

Several possibilities are available to manage Cookies. Any setting you may undertake may change your Internet browsing and your access to certain services that require the use of Cookies.

You can configure your browser so that Cookies are saved in your device or rejected (systematic rejection or according to their issuer). You can also configure your browser so that the acceptance or rejection of Cookies are offered to you punctually, before a Cookie is likely to be registered in your terminal.

For the management of cookies and your choices, the configuration of each browser is different; it is your responsibility to refer to your browser instructions or the help screen. This configuration is described in the help menu of your browser, which will allow you to know how to change your wishes for Cookies.

As an indication, and without our being able to guarantee its proper functioning, you can find instructions on the various browsers at the following (temporary or definitive) addresses.

You want to disable cookies; you will find below the manipulations to perform on the main browsers:

Internet Explorer

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

Mozilla Firefox

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Safari

https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Google Chrome

https://support.google.com/chrome/answer/95647?hl=en

If your browser is not in the list or if the previous link changed, you can search in your browser with these words: ‘yourbrowser cookies management’ (where yourbrowser is Firefox, Chrome…).

Conservation duration

Cookies deposited on your terminal are kept for a maximum of 13 months. Once their conservation duration expires, Cookies will be deleted.