PRIVACY AND COOKIES CHARTER
Last revised: January 17th, 2023
Welcome to COSTER ASSOCIATES!
The purpose of this privacy and cookies charter (the ‘Charter’) is to formalize our commitment to respecting the privacy of users of the www.costerassociates.com website (“Website”), as well as users of our services (“Services”), our partners, our suppliers, our prospects…
As part of our services, we might process your personal data in compliance with the General Data Protection Regulations 2016/679 (‘GDPR’), the Cyber Security Law of the People’s Republic of China (‘Cybersecurity’), the Personal Information Protection Law of the People’s Republic of China (“PIPL”) and under the conditions set out below.
Personal data means any information relating to an identified or identifiable natural person. We collect and process personal data in the context of providing our Services or communicating about these Services exclusively, in strict accordance with the GDPR, Cybersecurity, and PIPL.
We only collect personal data that is adequate, relevant and limited to what is necessary with regard to the purposes for which it is processed. Thus, you will never be asked to fill in personal data considered to be ‘sensitive’, such as your racial or ethnic origins, your political, philosophical or religious opinions.
By browsing our Website, contacting us regarding our Services, attending our events, being our client, partner, supplier etc., you authorize us to process your personal data in accordance with this Charter. If you do not accept the terms of this Charter, please refrain from using the Website and the Services.
1. In what cases do we collect your personal data and what data is collected?
We may collect and store your personal data, especially when you:
- browse the Website,
- use our Services,
- are a partner,
- are a supplier,
- register to one of our events, either organized by us or in which we are speaker,
- contact us.
We use your personal data to enable the implementation and management of the Website and of our Services and to respond to your specific requests. We also use your personal data for the purpose of operating and improving our Services, our Website and our approach. This information is used only by us and allows us to better tailor our Services to your expectations.
1.1 Navigation on the Website
1.1.1. Connection data: each time you connect to our Website, we collect personal data such as, in particular, your IP address and the MAC address of your computer, the date and time of connection, as well as information about the browser you are using.
1.1.2. Navigation data: we also collect information to identify how you access the Website, which pages are visited and for how long. In this context, we may use Cookies as specified in paragraph 5 below.
1.2 Use of our Services
Each time you access our Services, we will collect personal data such as your name, phone number, email address, postal address, and any other personal data deemed necessary for the provision of our Services or that you would decide to share with us willingly.
1.3 Partnership
If we have entered into a partnership agreement for the provisions of part of our Services for instance or for any other reasons, whether the partnership is in writing or not, we might have to process your personal data, such as your name, phone number, email address, postal address, and any other personal data deemed necessary for the completion of our partnership.
1.4 Suppliers
If you are one of our suppliers, whether our agreement is formalized in writing or not, we might have to process your personal data, such as your name, phone number, email address, postal address, and any other personal data deemed necessary for the completion of our agreement.
1.5 Registration to our events
If you are an attendant to one of our events, whether directly organized by us or nor, or in which we are a speaker, we might have to process your personal data, such as your name, phone number, email address, postal address, and any other personal data deemed necessary to serve you better or that you would decide to share with us willingly.
1.6 Contacts
If you have decided to contact us directly or through our Website or social media, we might have to process any personal information that you will have shared with us willingly, such as your name, phone number, email address, postal address, and any other personal data that you would decide to share with us willingly.
2. How do we protect your personal data?
We have implemented technical and organizational security measures to guarantee the security, integrity and confidentiality of all your personal data, in order to prevent it from being distorted, damaged or accessed by third parties. We ensure an appropriate level of security, taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the processing as well as the risks and their probability.
HOWEVER, IT IS SPECIFIED THAT NO SECURITY MEASURE BEING INFALLIBLE, COSTER ASSOCIATES IS NOT ABLE TO GUARANTEE ABSOLUTE SECURITY TO YOUR PERSONAL DATA.
3. In what cases do we share your personal data?
3.1 Sharing your personal data with third-party companies
When you browse the Website, your personal data may be transmitted to external service providers. These third parties provide services on our behalf such as analytics.
In addition, we might have to share your personal data with other service providers used by us, such as accountants, etc.
Personal data may be transferred to countries outside the European Union (such as the United Kingdom, the United States and the People’s Republic of China) for the purpose of processing your requests, entering the formalities and to host and secure personal data.
In accordance with the GDPR, all transfers of personal data to a country outside the European Union and/or not offering a level of protection considered sufficient by the European Commission have been the subject of cross-border flow agreements conform to standard contractual clauses issued by the European Commission. Other transfers of personal data to the United States, in particular for customer relationship management (CRM), are governed by the E.U. – U.S. PRIVACY SHIELD (European Union-United States Data Protection Shield). Other transfers of personal data to the People’s Republic of China are governed by the Cybersecurity Law and Personal Information Protection Law.
Except in the case where a third party asks you to accept a confidentiality charter and conditions of use which are specific to it, the third companies having received communication of your personal data have undertaken to process your personal data only for the implementation of the Services. We will never share your personal data with third-party companies for marketing and/or commercial purposes without obtaining your prior consent.
4. How long do we keep your personal data?
We will only keep your personal data for as long as it is necessary for the provision of our Services, the completion of our agreements, or the legal duration prescribed by applicable laws and regulations.
In any event, we will keep your personal data for a period not exceeding that necessary with regard to the purposes for which they are processed in accordance with the uses set out in this Charter and in compliance with laws and regulations.
5. Cookies: how do we use them?
5.1 What is a cookie?
A cookie is a text file that can be placed in a terminal when consulting an online service with navigation software. A cookie file allows its issuer in particular, during its period of validity, to recognize the terminal concerned each time this terminal accesses digital content containing cookies from the same issuer.
In any event, the cookies deposited on your navigation terminal with your agreement are destroyed after the duration stated for each cookie in the cookies banner of our Website.
5.2 What are the cookies used on our Website for?
The cookies we issue are detailed in the customize section of our cookies banner that appears on our Website when browsing it for the first time.
The same content is also accessible from the floating cookies settings button, that appears once you have saved your cookies preferences from the cookies banner.
Five types of cookies might be used: necessary cookies, functional cookies, analytics cookies, performance cookies, advertisement cookies. You will be able to opt in or out of each one of them, keeping in mind that necessary cookies are essential to browsing our Website.
5.3 How can you control the cookies used?
You can modify or withdraw your consent at any time with regards to cookies from the customize section of our cookies banner that appears on our Website when browsing it for the first time, or from the floating cookies settings button, that appears once you have saved your cookies preferences from the cookie banner.
You can also configure your browser software at any time so that cookies are saved on your terminal or, on the contrary, that they are rejected (either systematically or according to their issuer). You can also configure your browser software so that the acceptance or refusal of cookies is offered to you from time to time, before a cookie can be saved in your terminal.
Please note: any configuration is likely to modify your browsing on the Internet and your conditions of access to certain services requiring the use of cookies. WE DECLINE ALL RESPONSIBILITY FOR THE CONSEQUENCES LINKED TO THE DEGRADED FUNCTIONING OF OUR SERVICES RESULTING FROM THE IMPOSSIBILITY OF SAVING OR CONSULTING THE COOKIES NECESSARY FOR THEIR FUNCTIONING AND THAT YOU WOULD HAVE REFUSED OR DELETED. This would be the case when we (or our service providers) could not recognize, for technical compatibility purposes, the type of browser used by your terminal, its language and display settings or the country from which your terminal appears to be connected to the Internet.
5.4 How to configure your navigation software?
For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to modify your preferences regarding cookies.
6. What are your rights?
Only you have communicated the data in our possession to us, through our agreements or through the Website. You have rights to your personal data. In accordance with the regulations on the protection of personal data, in particular Articles 15 to 22 of the GDPR and Chapter 4 of the PIPL, and after proving your identity, you have the right to ask us for access to personal data concerning you, the rectification or erasure thereof. In addition, within the limits set by law, you also have the right to object to the processing, to limit it, to decide the post-mortem fate of your data, to withdraw your consent at any time and to the right to portability personal data provided.
You can contact us in order to exercise your rights at the following email address: contact@costerassociates.lawyer by attaching a copy of an identity document to your request.
7. Can we modify the Charter?
We reserve the right to modify the Charter at any time. It is therefore recommended that you consult it regularly. If there are any changes, we will post those changes on this page and in places we deem appropriate based on the subject matter and the extent of the changes. Your use of the Website after any modification means that you accept these modifications. If you do not accept certain substantial changes to this Charter, you must stop using the Website and our Services.
