1 - Introduction
As part of its commercial activity as a press publisher on paper or digital media, and its derived commercial activities, Le Monde Diplomatique may process information concerning you. For example, by filling out a subscription form, making a purchase on our online store, contacting our Customer Service Department, registering for an event we are organizing, browsing our websites, clicking on a promotional link for the titles and services we offer, you are sending us information, some of which may identify you ("personal data").
This Privacy Policy informs you how we collect and process your personal data. We ask you to read it carefully.
Important
We use your personal data only in the circumstances provided for by current regulations:
• The performance of an agreement we have with you, and/or
• Compliance with a legal obligation, and/or
• Your consent to the use of your data, and/or
• The existence of a legitimate interest in using your data. A legitimate interest is a set of commercial or business reasons that justify the use of your data by Le Monde Diplomatique.
For Le Monde Diplomatique, this legitimate interest is mainly to maintain the level of commercial revenues necessary to maintain its independence as a press organization, to finance the production of quality editorial content offered to its readers, to maintain the free availability of certain content on its sites or the existence of special subscription offers for certain categories of subscribers (students, etc.).
We believe that this legitimate interest, of a commercial nature, is part of a broader framework for maintaining a free and independent press, an indispensable vector for freedom of expression and freedom of opinion in a democratic society.
By agreeing to receive promotional information from our publications and partners, you are helping to ensure the economic viability of our newspaper publishing business.
In any event, your individual rights will always take precedence over our legitimate interest, and we will never use your data for commercial purposes against your will.
If you have any questions about this document, you can contact the Data Protection Officer of Le Monde Diplomatique (dpo@mondediplo.com).
2- Who is the controller of the data processing referred to in this document?
The controller of the data processing operations referred to in this document is Le Monde Diplomatique, a société anonyme (French public limited company) with a capital of €6,600,000, registered in the Paris Trade and Companies Register under number B 400 064 291, whose registered office is located at 1, rue Stéphen-Pichon, 75013 PARIS, of which Mr Serge Halimi, Chairman of the Management Board, is the legal representative.
The Data Protection Officer of Le Monde Diplomatique is Ms Juliette Boukobza.
3- What data do we collect about you and under what circumstances do we collect it?
3.1 The data you transmit directly to us
During the various contacts we have with you, you may be asked to provide us with information concerning you. This information is collected in particular when you take out a subscription, create an account on our sites and applications, place an order on our online shop, or access any other offer or service.
Such data includes:
• Names, forenames, title and date of birth;
• Postal address, e-mail address and telephone number;
• Information necessary for the delivery or the carriage of an ordered product;
• Username and encrypted password used to identify you on our sites or applications;
• Encrypted information relating to your means of payment (in particular credit card number);
• Choice with regard to commercial prospecting;
• Any other information you wish to bring to our attention.
3.2 Data we collect in connection with our business relationship
The data we collect in connection with our business relationship with you includes the following:
• Information relating to the history of your commercial relationship with Le Monde Diplomatique: subscriptions taken out, orders for products and services, if applicable invoicing and payment;
• Your participation in promotional offers or events;
• Requests you have made to our customer service or problems you have reported to us, for example concerning the delivery of our products or the performance of our services;
• Information concerning purchases of products and services that you have made from our partners.
3.3 Data we collect automatically
Each time you visit our sites and applications, we collect information about your connection and navigation. Various technologies may be used to collect this data. The principal one is a cookie.
• Data collected via cookies
Cookies have various functions, such as enabling you to navigate efficiently on a site or application, remember your choices, the goods and services you wish to purchase and offer you promotional content for our titles and services relevant to your interests expressed during your browsing. You will find more information about cookies on the following websites:
The cookies deposited by Le Monde Diplomatique subject to your choices give us access to the following information:
- Identifiers of the equipment you use (IP address of your computer, Android identifier, Apple identifier, etc.),
- Type of operating system used by your device (Microsoft Windows, Apple Os, Linux, Unix, BeOS, etc.),
- Type and version of the browser software used by your device (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox, Google Chrome, etc.),
- Dates and times of connection to our services,
- Address of the web page from which you came ("referrer"),
- Navigation data on our services and content viewed.
• Data collected by standard Internet technologies
We may also use standard Internet technologies, such as scripts, pixels and redirects. Scripts (sometimes called tags), written in javascript, are programs that run in your browser and perform various actions, for example send information to our servers. Scripts are also capable of creating pixels. Pixels (sometimes called transparent GIFs, clear GIFs or Web-bugs) are lines of code that display a graphic image (usually invisible) on a web page or in an e-mail. Redirects are used to make a web page available under multiple page addresses (URLs). When a browser opens a redirect URL, a page with a different URL is opened.
The purpose of these technologies is to enhance your experience on our sites and applications, including providing you with content tailored to your interests. For example, when a user clicks a sharing button on an item, a script creates a pixel that counts the shares. Thus, we are able to determine the total number of shares of an item, and we can establish the ranking of the items most commonly shared.
These technologies give us access to the following information:
- Information about your use of our sites and applications;
- Information about whether cookies are present on your device, the time and date a page is viewed, and a description of the page where the web tag is placed;
- Information about whether or not you read the e-mails we send you and about clicks you make on the links contained in those e-mails.
Our sites and applications may also include third-party scripts, pixels and redirects. Such technologies allow third party service providers to collect certain information such as your browser type, and the website that redirected you to our websites. These third-party service providers process the information they collect for audit, research, and reporting purposes on our sites. We do not share your personally identifiable information with these third parties in connection with their use of these technologies.
3.4 Data relating to minors
In principle, our products and services are intended for adults who are legally capable of entering into contractual obligations.
The minor user must obtain the consent of his/her legal representative prior to the communication of personal data concerning him/her.
For registration on our sites and some of our online services (newsletter for example), the age of 16 is accepted.
An Internet user under 18 years of age at the time of publication or creation of an online account has a specific right to the deletion of data concerning him/her. For further information, please contact la déléguée à la protection des données du Monde Diplomatique (dpo@mondediplo.com).
3.5 Third Party Data
Before giving a third party a subscription or any other product or service that we market, you must ensure that the person concerned accepts that their personal data, particularly their postal details, are communicated to us.
3.6 Exclusion of Sensitive Data
Le Monde Diplomatique does not collect any sensitive data about you. Sensitive data includes racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data or sexual orientation. If such information is in any manner communicated to us, it will be deleted.
4- For what purposes do we use your data?
This article describes the main purposes for which we use the data referred to in article 3.
4.1 Operations necessary for the supply of products or services
• Inclusion and fulfilment of your subscription contract for our publications;
• Taking into account your order for products or services and fulfilment of such order;
• Management of subscriptions to our newsletters and/or e-mail alerts;
• Invoicing; collection of payments;
• Management of deliveries and follow-up of orders;
• Customer Services: provision of a Customer Service accessible by mail, telephone, e-mail or instant messaging chat, for any enquiries or complaints;
• Conducting satisfaction surveys;
• Providing information on the modification or development of our services;
• Management of unpaid debts and litigation;
• Management of the exercise of your rights over your personal data, under the conditions provided for in Article 9;
• Verification of compliance with applicable legislation, our agreements and general conditions of use.
4.2 Commercial prospecting operations relating to Le Monde Diplomatique’s publications, products and services
• Compliance with postal standards, updating, enrichment and deduplication of your personal information in a dedicated Le Monde Diplomatique database;
• Sending information about our company, its publications and its activity;
• Sending promotional offers relating to our products and services by postal mail, piggyback mailing, e-mail, mobile notifications, on social networks or any other medium;
• Customized loyalty or sales prospecting actions;
• Implementation of promotional operations;
• Collection of customer reviews;
• Development of trade statistics.
4.3 Operations related to commercial partnerships
• File sharing, exchange or rental with business partners in compliance with current regulations and security requirements;
• Sending promotional messages relating to products and services of partners by postal mail, piggyback mailing, e-mail, mobile notifications, on social networks or any other medium;
• Setting up promotional or event operations with commercial partners.
4.4 Purposes associated with the deposit of cookies on your browser
• Operation and optimization of navigation on our sites and applications
- Adaptation of the presentation of our sites and applications to the display preferences of your terminal (language used, display resolution, operating system, etc.) during your visits, depending on the viewing or reading hardware and software that your terminal contains; -* Memorization of information relating to a form that you have completed on our site (registration or access to your account) or to products, services or information that you have chosen on our site (service subscribed, content consulted, purchase made, etc.);
- Automatic connection to reserved or personal areas of our site, such as your account, through usernames or data that you have previously entrusted to us;
- Provision of sharing tools on social networks;
- Management of our platforms and completion of internal technical operations as part of problem solving, data analysis, tests, research, analyses, studies and surveys;
- Implementation of security measures;
- Quality measures to ensure that our content display is appropriate for your device.
• Attendance and audience measurement
- Establishment of statistics and volumes of frequentation and use of the various elements composing our site (sections and contents visited and routes) in order to improve the interest and ergonomics of our services;
- Accounting for the total number of promotions of our titles and services displayed by us on our advertising space, ranking and statistics;
- Analysis of audiences based on the results of promotional campaigns;
- Determination of interests and behaviour;
- Improved customer/reader-user awareness for customization purposes.
• Personalization of the promotions on our sites
- Adapt the promotional spaces for our titles and services to the display preferences of your terminal (identification of advertisements, statistics and volumes of frequentation and use of the various elements composing our site: sections and contents visited and routes) in order to improve the interest and ergonomics of our services;
- Adapt the promotions for our titles and services displayed on your device when you browse our sites and applications to its technical characteristics (1), to your previous browsing choices (2), to your interests and uses (3), to the data you previously communicated to us (4), if applicable, to the geographical location data of your device (5);
5- How long do we retain your data?
Your personal data will be retained for a period of time in accordance with the legal provisions or in proportion to the purposes for which it was recorded. Certain retention periods correspond to the legitimate interest of Le Monde Diplomatique as specified in the introduction.
Retention periods vary depending on whether we have an ongoing contractual relationship (you are an active customer), whether we have had a contractual relationship with you in the past (you are an inactive customer) or whether we have never had such a relationship with you (you are a prospective customer). The data related to your browsing on our online services collected by cookies that you have authorized have a specific retention period.
The table below lists the main retention periods for your data.
In any event, we regularly review the information we hold. When its retention is no longer justified by legal, commercial or customer account management requirements, or if you have made use of a right to modify or delete it, we will delete it securely.
| Categories of data | Purposes | Retention periods |
|---|---|---|
| Data relating to a prospect | ||
| All data | Constitution and management of a prospect file | 3 years from data collection or the last contact from the prospect |
| Data relating to an active customer | ||
| All data | Management of a customer file | For the duration of the contractual relationship |
| Data relating to an inactive customer | ||
| Data relating to the performance of the contract | Management of customer account, orders, deliveries, invoicing and payments | 10 years after the end of the contract or the last contact from the inactive customer |
| Identification and contact data – Inactive customers | Submitting information on the development of our publications and offers | 5 years after the end of the contract or the last contact from the inactive customer (10 years for the surname, forenames, and postal address) |
| Identification data – Digital subscribers | Submitting information on the development of our publications and offers | 5 years after the end of the contract or the last contact from the inactive customer |
| Identification and contact data – Newsletter subscribers | Submitting information on the development of our publications and offers | 3 years from unsubscribing or last contact from customer |
| Identification and contact data – Web Account subscribers | Submitting information on the development of our publications and offers | 3 years from unsubscribing or last contact from customer |
| Identification and contact data – Mail order purchasers | Submitting information on the development of our publications and offers | 5 years after product delivery or last contact from inactive customer (10 years for the surname, forenames, and postal address) |
| Data generated by cookies | ||
| Data related to your navigation on our online services | Operation and optimization of services Frequency of use measures Personalization of content and advertising |
13 months maximum |
6- Who is likely to have access to the data we collect?
6.1 Access to data for services managed jointly with Le Monde Group departments
Employees in the subscription, customer relations, administrative, accounting, IT and marketing & sales departments may have access to some of your data. Access to your data is based on individual and limited access authorizations. Personnel who can access personal data are subject to an obligation of confidentiality (by a personal and nominal commitment of confidentiality).
6.2 Transmission of data
The following are likely to have access to some of your data:
• Subcontractors They provide services on our behalf, particularly:
- Management of your subscription
- Secure online payments and anti-fraud measures
- Shipping of orders
- Management of telephone calls, postal or digital mailings
- Customization of content for mobile sites and applications
- Carrying out maintenance operations and technical development work
- Collection of customer opinions
- Provision of analytical solutions or audience measurement statistics
Our subcontractors have access to your data on the basis of signed contracts specifying their obligations in terms of data security and confidentiality protection.
• Social networking platforms The use of social networks to interact with our sites and applications (notably the "share" buttons on Facebook, Twitter and Google+) is likely to lead to data exchanges between Le Monde Diplomatique and such social networks. For example, if you are connected to the Facebook social network and you visit a page on www.monde-diplomatique.fr Facebook may collect such information. Similarly, if you visit an article on www.monde-diplomatique.fr and click on the “Twitter” button, Twitter will collect this information. We therefore ask you to consult the personal data management policies of the various social networks to learn about the collections and processing they perform on your data.
• Business partners
They promote products or services on their own behalf. We draw your attention to the fact that if you decide to subscribe to the products or services of our business partners and you grant them access to some of your information, in particular by connecting to their sites or applications, their privacy policies and their deposits of cookies are binding on you. We have no control over the collection or processing of your data by our business partners on their own platform.
• Police, judicial or administrative authorities
When we have a legal obligation to do so or in order to guarantee the rights, property and security of Le Monde Diplomatique.
7- Is your data transferred outside the European Union?
We store your personal data in the European Union. However, it is remotely possible that the data we collect when you use our platforms or as part of our services may be transferred to subcontractors or business partners located in other countries, some of which may have less protective data protection legislation than that currently effective in the country where you reside. In the event of such a transfer, we ensure that processing is carried out in accordance with this Privacy Policy and is governed by the European Commission’s standard contractual clauses which ensure an adequate level of protection of the privacy and fundamental rights of individuals.
8- How is your data protected?
As data controller, we implement appropriate technical and organisational measures in accordance with applicable legal provisions to protect your personal data against alteration, accidental or unlawful loss, use, disclosure or unauthorised access, and in particular:
• The appointment of a data protection officer;
• The creation of a unit dedicated to the security of information systems;
• Raising awareness of the confidentiality requirements of our employees who have access to your personal data;
• Securing access to our premises and IT platforms;
• The implementation of a general IT security policy for the company;
• Securing data access, sharing and transfer;
• A high level of data protection when selecting our subcontractors and partners.
9- What are your rights?
9.1 Your right of access to your personal data
You have the right to access to your personal data and to request that it is corrected, completed or updated. You may also request the deletion of your data or object to its processing, provided you have a legitimate reason.
You may ask to exercise your right to the portability of your data, i.e. the right to receive the personal data you have provided us with in a structured, commonly used format and the right to transmit this data to another controller.
Finally, you may formulate guidelines concerning the storage, erasure and communication of your personal data after your death.
You can exercise your rights by contacting the Data Protection Officer of Le Monde Diplomatique at the following address: 1 avenue Stephen Pichon, 75013 Paris or by e-mail: dpo@mondediplo.com.
Before responding to your request, we may verify your identity and/or ask you to provide us with more information to respond to your request. We will endeavour to respond to your request within a reasonable time and, in any event, within the time limits set by law.
In the event of an unsatisfactory response, you may lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL).
9.2 Your rights to object to commercial solicitations
We may use your contact information for marketing purposes in accordance with applicable law and the terms of this Privacy Policy. You may at any time object to such solicitations, in accordance with terms that depend on the communication channel that we use to send them to you.
• Commercial solicitations by electronic means (e-mail and SMS):
We comply with the rules of Article L.34-5 of the Postal and Electronic Communications Code, which provides for the prior and express collection of your consent for sending commercial prospecting by electronic means (e-mail, push notifications or SMS).
Thus, on the forms you complete when you subscribe to one of our products or services, when you create an account on our sites or applications, or when you make any other contact with us, you are expressly asked for your consent:
- to receive offers from Le Monde Diplomatique
- to receive offers from partners of Le Monde Diplomatique
Exception: your express prior consent is not required if you are already a customer of Le Monde Diplomatique and the purpose of our solicitation is to offer you products or services similar to those we already provide.
In any event, you always have the option of objecting to the receipt of such solicitations by taking the following actions:
- For e-mail, by clicking on the unsubscribe link provided in each e-mail, by visiting your online account or by contacting our service department (click).
- For SMS, by sending a STOP SMS to the number specified in it or by contacting our customer service department (click).
• Solicitations by any other means
Please contact our customer service department (click) if you wish not to be contacted.
9.3 Your rights regarding the acceptance and management of cookies
The recording of a cookie on your navigation device is subject to your consent. You may change your choices about whether or not to accept cookies placed on your device, either on your browser or online with different operators, at any time.
In order to manage cookies as closely as possible to your wishes, please set your browser to take account of the specific purpose of cookies. How to exercise your choices?
• (a) Make your choices on your browser
You can set your browser software to either accept or reject cookies from time to time, before a cookie is likely to be stored, or to automatically accept or reject cookies being stored on your device.
We should warn you that any setting on your browser software regarding the rejection of technical and functional cookies may affect your browsing experience on our websites, or even prevent the use of some of our services requiring the use of such cookies.
Where applicable, we decline all responsibility for the consequences linked to the degraded functioning of our websites and our services resulting from our inability to record or consult the cookies necessary for their functioning and which you have refused or deleted.
For the management of cookies and your choices, the configuration of each browser is different. It is described in your browser’s help menu, which will enable you to find out how to change your cookie preferences.
• “Do not track” You can also set your browser to send a code advising websites that you do not wish to be tracked (option « Do not track »).
(b) Make your choice online
• For audience measurement cookies and analytical cookies
Analytical cookies enable us to obtain anonymous statistics on visits to our site in order to optimise it and detect any malfunctions. They are registered on our sites and applications by the company ATInternet (XiTi).
If you do not want our sites and services to store cookies in your browser for audience measurement purposes, you can click on the following link where you will find additional information:
