This document details the various measures implemented by INA to ensure, in accordance with Regulation (EU) 2016/679 otherwise known as the General Data Protection Regulation ("GDPR") and amended Data Protection Act No. 78-17 of 6 January 1978 that apply when you browse the INA website, hereinafter referred to as "the Website" as defined in the General Conditions of Use.
1. Subscription to the Website newsletter and to email notifications
The newsletter service is a specific use of personal data managed by INA under the conditions defined below:
- Purpose and legal basis
If you have chosen to receive our newsletter, we will use your personal data (e-mail address) under the conditions defined herein to keep you informed (by email) of developments in our products and services. The legal basis for this is legitimate interest.
- The types of data we are processing for this purpose are: data on identity (first name, surname), email address, date of subscription/unsubscription, behaviour data (date of first/last delivery of a marketing email, date of opening of first/last marketing email, date of first/last click on a marketing email, number of emails, etc.).
- Collecting the e-mail address is mandatory for us to send you the newsletter.
- Data subjects. The data used is solely about people wishing to subscribe to the Website newsletter.
- Who the data is for. The data is for the INA sales department.
- How long the data is kept. All emails sent contain an unsubscribe link which allows you to cancel your subscription automatically. INA keeps your e-mail address for 3 (three) years from the last date of contact. If you unsubscribe using the link, your details will be removed from the mailing list within a reasonable time.
- Transfer of data outside the EU. As part of the running of the newsletter, the user’s personal data may be transferred to an INA service provider in the USA. This company’s addressees will be sent the following data: email address, unsubscribe and consent data, behaviour data (date of opening of first/last marketing email, date of first: last click on a marketing email, number of emails, etc.). As the United States is not subject to a European Commission adequacy decision, a convention of cross-border data-flows consistent with European Commission standard contractual clauses has been reached with this company, in order to define the terms of data transfer and to ensure a sufficient level of protection under the requirements of the GDPR and Data Protection Act.
2. Contact form
The Website gives you access to a contact form, through which you are invited to supply information. The Website contact form processes personal data managed by INA under the conditions defined below:
- Purpose and legal basis. The processing concerns requests made by Website users. In particular, it is designed to receive user requests by electronic means via our web form and to archive such messages. This process allows us to respond to your requests. The legal basis for this data process is that of legitimate interest.
- The data types processed are: those relating to your identity, your contact information (e-mail address, phone number), the subject of the request, the date, the browser and the operating system, and the answer provided;
- Mandatory data collection. Data marked with an asterisk is mandatory for the proper processing of your request. If any mandatory field is left blank, the form cannot be validated.
- Data subjects. The data processed concerns Website users who wish to make an enquiry related to the Website.
- Data recipients. The data gathered via the form is sent either to INA or to a service provider selected by INA to deal with your enquiry.
- Data retention period. The enquiries and the responses to them are kept for 3 years from the completion of your enquiry.
- Transfer of data outside the EU. No data is transferred out of the EU.
3. Creation and management of user accounts
The creation and management of a user account is a process managed by INA under the conditions defined below:
- Purpose, legal basis and classes of data used. In accordance with our end-user license agreement (CGU), setting up a user account allows access to Website services. Following the set-up of a user account after an access request, INA uses data related to your marital status, your identity, professional life and connection data (IP address, logs, etc.).
The legal basis for this usage is the execution of a contract or its prerequisites (when you request access), the setting up of a user account requires acceptance of our end-user license agreement (CGU).
- The data types collected are: those related to your identity (first name, surname), your professional life (occupation, position), professional contact details (phone number, email address), country, locality, connection data (IP address, logs, etc.).
- Necessity for data collection. The data collected from the access form is strictly necessary, and if the mandatory data requested on the web form is not supplied, the request to create an account will not be processed.
- Data subjects. These are individuals who have requested access to the Website services.
- Data recipients. The data is for the INA sales department
- Transfer of data outside the EU. No data is transferred out of the EU.
- Data retention period. Data is kept for the duration of the contractual relationship i.e. for the duration of the access. The access is valid up to the closure (deletion) of the user account. When the account is deleted, the associated data is archived for the period prescribed by law and then deleted. The data passed to INA for an access request with no setting up of a client account will not be kept and will be automatically deleted one month after the date of the request for access.
In accordance with article 3 of our end-use license agreement, INA reserves the right to suspend an account if there is suspicion of abnormal use of the viewing of site contact.
We are likely to install cookies on your computer, mobile or tablet during your use of our Website in order to improve the interactivity of the Website and our services.
4.1 What is a "cookie"?
A “cookie” is a small file, usually holding letters and numbers, sent by the internet server to your browser and stored on your device. There are different types of cookies for different purposes.
Most cookies can also be managed in your internet browser.
4.2 Issuers of cookies
4.2.1 Cookies issued by INA
Cookies may be deposited on your device by INA to assist with navigation on our Website.
4.2.2 Third-party cookies
Cookies may be deposited on your device by third-party companies to analyse use of our Website. These third-party cookies may be deposited on your device while you are using the Website. INA does not always have control over third-party cookies deposited by its partners, who act independently. Where appropriate, and within reason, we will refer you to the tools made available by our partners to manage third-party cookies.
4.3 Different types of cookies
Several types of cookies are used on our Website for different purposes.
4.3.1 Operating cookies
Operating cookies are installed by INA, for which your consent is not required, and are strictly necessary for the Website to work. They allow you to use the main features of the Website. Without them, you would probably be unable to use our Website.
List of essential cookies on the Website:
Saves session parameters
Expires at the end of the session*
Saves the player sound settings
*At the end of your session (browser closed), the cookie will be deleted
If you block the saving of these cookies, you may not be able to use all our Website’s functionality.
4.3.2 Third-party cookies on the Website
- Audience measurement cookies
INA uses the AT Internet service, which does not require consent, to measure the Website’s audience. For this, audience measurement trackers are deposited on visitors’ devices to get information about the sites they visit. These trackers allow INA to see how users arrived at the Website, count the number of visitors and map their route.
AT internet cookies
This cookie is used to track the frequency and duration of visits to the site. It also tracks how many and which pages a visitor to a site goes to. This information can be used by the site to optimise the domain and its pages.
Expires at the end of the session*
Main visitor ID
List of numsites visited
Digital username, supplied by the client when a user connects to their site.
Technical value of the management of the visitors identified (xtan/xtat)
At INA’s request, the AT Internet solution is parameterised to make the data collected entirely anonymous, and so does not require your authorisation (more information here). At any point you can withdraw consent to the use of your personal navigation data by going to the opt-out page:“Activating the opt-out option".
The audience measurement trackers are kept for 13 months.
The data collected by the cookie is retained for 25 months. The data is then deleted.
- Social network cookies (social buttons)
These are third-party cookies which facilitate sharing of pages and content of our Website on the social media platforms. They allow you, for example, to “like” a page and share information from our Website with your friends on social media networks.
The INA does not use these types of buttons on its Site. However, you will find a button to let you follow our Website on the professional social media network LinkedIn. By clicking on this button, you will go to the social media network LinkedIn, which could load cookies onto your device.
For more information on the use of your personal data by the social network LinkedIn, you can read its confidentiality policy here: https://www.linkedin.com/legal/cookie-policy?_l=fr_FR
5. Non-disclosure and security of personal data
The personal data collected through the INA Website will under no circumstances be disseminated, transferred, rented or exchanged by INA to third parties without your consent. However, for us to comply with our legal and regulatory obligations, your personal data may be transmitted to competent authorities.
INA is committed to ensuring the protection of your personal data by applying industry-standard protection technology for encoding information transmitted online. These technologies and procedures for protecting your personal information [are designed to] prohibit access to, use by and disclosure to unauthorized persons. INA cannot be held responsible for the content of sites referred to by links on our Website, nor their level of security nor their data protection practices.
6. Your personal data rights
In accordance with the provisions of the European Regulation (EU) 2016/679 and the amended “Data Protection” Act No. 78-17 of 6 January 1978, you have a right to access, rectify, erase, restrict or limit the processing of your data , as well as the right to determine the use of your data after your death.
You can exercise these rights by sending an email to firstname.lastname@example.org, or by post to the Data Protection Officer: à l’attention du Délégué à la protection des données, Direction Juridique,4 avenue de l’Europe 94366 Bry-sur-Marne Cedex, enclosing a copy of an identity document. You can also contact the Data Protection Delegate via the contact form.
You also have the right to lodge a complaint with the (French) data protection authority, CNIL.
Last update: July 2021