Privacy Policy

last update: September 13th 2020

PREAMBULE

 

This Privacy Policy informs you about how Eurasia Marketplace uses and protects the informations you provide to them, where applicable, when you use the Website accessible through the following URL: www.click2rail.com (hereinafter referred to as the « Website »). Please note that this Privacy Policy may be modified or completed at any moment by Eurasia Marketplace, in particular to comply with any legal or technological developments. In such a case, the date of its update will be clearly identified at the top of this Policy. These modifications apply to the user as soon as they have been informed that the Privacy Policy has been updated or as soon as it is published online.

 

ARTICLE 1.PARTIES

This Privacy Policy is applicable between the Website editor, hereinafter referred to as " Eurasia Marketplace ", and any person connecting to the Website and/or using the Software, hereinafter referred to as "the User".

 

ARTICLE 2.DEFINITIONS

« Website Contents»: elements of any kind published on the Website, whether protected by an intellectual property right, such as texts, images, designs, presentations, videos, diagrams, structures, databases or software. 

« User »:  any person connecting to the Website.

« Website »: Website accessible at the URL www.click2rail.com, as well as sub-sites, mirror sites, portals and URL variations related.

 

ARTICLE 3.SCOPE

This Privacy Policy is applicable to all Users. By clicking on "I accept" when registering on the Website, you fully and completely accept it. Likewise, clicking on "I accept" in the information banner relating to cookies displayed on the Website will confirm your acceptance, while allowing you to personalize the cookies that may or may not be applied to you. You also acknowledge that you are fully aware of this fact and accept them without restriction. Regarding the management of cookies on the Website, we invite you to read our cookie policy.

The User acknowledges the evidential value of Eurasia Marketplace's automatic registration systems and, in the absence of proof to the contrary, waives the right to contest them in a litigation.

Acceptance of this Privacy Policy supposes on the part that the Internet User has the legal capacity to do so or is at least 16 years old, or has the authorisation of a guardian or a trustee if they are incapable, of their legal representative if they are under 16 years old, or that they hold a power of attorney if they are acting on behalf of a legal entity.

 

ARTICLE 4.PERSONAL DATA

In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on 14 April 2016 and the national legislation in force, Eurasia Marketplace provides you with the following information:

 

4.1. Identity of the Data Controller

The person responsible for the collection and data processed on the Website is Eurasia Marketplace, French simplified joint stock (société par actions simplifiée), having its registered office at 66 avenue des Champs Elysées,75008 Paris, Commercial Register ID (SIREN): 839224896, anastasia.dyakonova@eurasiamarketplace.com

 

4.2. Identity of  the Data Protection Officer (DPO)

The Data Protection Officer is Deshoulières Avocats Associés, 121 boulevard de Sébastopol 75002 Paris, telephone: +33.1.77.62.82.03, rgpd@deshoulieres-avocats.com, www.deshoulieres-avocats.com.

 

4.3. Data Collection by Eurasia Marketplace

 

4.3.1. Data collected  

 

4.3.1.1. Data collected during browsing and via Cookies

While browsing the Website, you consent to Eurasia Marketplace collecting information relating to: your use of the Website; the content you consult and click on; your demographic data; the connection data (times, pages viewed, IP address…)

For further information on the setting and use of cookies, please refer to our Cookies Policy

 

4.3.1.2. Data collected when using the contact form

The use of the contact form by the User supposes the collection by Eurasia Marketplace of the following personal data: last name, first name, email address*, phone number.

The information followed by an asterisk is required for the use of contact form.

Users who do not wish to provide this information will not be able to send a message to Eurasia Marketplace directly from the Website.

4.3.1.3. Data collected when using the registration form

The use of the registration form by the User implies the collection by Eurasia Marketplace of the following personal data: surname, first name, email address, telephone number.

Users who do not want to provide the information required to use the registration form will not be able to register directly from the Website.

 

4.3.1.4. Data collected when using the newsletter form

Within the framework of the use of the newsletter form, Eurasia Marketplace may collect and process your email address.

4.3.2. Purpose of the collection of personal data

The data collected during browsing are automatically processed to:

  • ensure and improve the safety of our services ;

  • develop, operate, improve, provide and manage the Website;

  • send information and contact people, including by e-mail;

  • avoid any illicit or illegal activity;

  • ensure compliance with the terms and conditions relating to the use of the Website

 

 The data collected during the use of the contact form are automatically processed to:

  • verify the identity of persons;

  • provide a detailed answer to the User;

  • ensure and improve the safety of our services;

  • develop, operate, improve, provide and manage the Website and/or the app;

  • send information to and contact the User, including by email and by telephone ;

  • ensure compliance with the terms and conditions relating to the use of the Website.

 

The data collected during the use of registration form are automatically processed to:

  • verify the identity of persons;

  • communicate with Users;

  • registering Users and providing our services;

  • ensure and improve the security of our services;

  • develop, operate, improve, provide and manage the Website;

  • send information to and contact the User, including by e-mail, telephone;

  • share content on the Website with other people or to let these other people know about their consultation or opinion, via the social network sharing buttons

  • contextualize and improve the User's experience ;

  • avoid any illicit or illegal activity;

  • ensure compliance with the terms and conditions relating to the use of the Website.

 

The data collected during the use of the newsletter form are automatically processed to:

  • send newsletters to the User ;

  • send commercial proposals;

  • send information to the User, including by email or by telephone;

  • avoid any illicit or illegal activity;

  • ensure compliance with the terms and conditions relating to the use of the Website. 

 

4.3.3. Legal basis for processing

The data collected during browsing have, as a legal basis, the legitimate interest of Eurasia Marketplace, namely, to carry out an analysis of behaviors on the Website, and to obtain an improved safety and functioning of the Website. Some of this data, such as the ones resulting from the implementation of some cookies, can have as their legal basis the consent of individuals.

The data collected during the use of the contact form have, as a legal basis, the consent of the persons concerned.

The data collected when using the registration form are based on the performance of the contract.

The data collected during the use of the newsletter form have, as a legal basis, the consent of the concerned persons.

 

4.3.4. Data Recipients

The collected data can only be viewed by the employees in charge of Customer or Website management and by the executive Board of Eurasia Marketplace. Those data are never made freely viewable by a third person.

 

4.3.5. Retention period for personal data

The personal data collected during browsing are kept for a reasonable period of time, necessary for the proper administration of the Website and for a maximum of 12 months, or until the withdrawal of the consent of the persons concerned.

The personal data collected during the use of the contact form are kept for a reasonable length of time necessary for the proper management of the request of the User and for a maximum of 12 months.

The data collected during the use of the registration form are kept for the duration of the contractual relationship between Eurasia Marketplace and the User, and for the period for which Eurasia Marketplace may be held liable

The data collected during the use of the newsletter form are kept until the withdrawal of the consent of the persons concerned.

At the end of each of these periods, Eurasia Marketplace will archive those data and keep them for the time during which Eurasia Marketplace can be held liable.

After the retention period, Eurasia Marketplace undertakes to permanently delete the data of the persons concerned.

 

4.3.6. Security and confidentiality of personal data

Personal data are kept in secured conditions, within the current technological means, in accordance with the provisions of the General Data Protection Regulation and national legislation in force.

 

4.3.7. Minimisation of personal data

Eurasia Marketplace may collect and process any data transmitted voluntarily by the User, in particularly while using the free field of the contact form.

Eurasia Marketplace directs the Users as much as possible when they provide useless or superfluous personal data.

Eurasia Marketplace undertakes to only keep and process the data strictly necessary for its activities and will delete any useless data received as soon as possible.

 

4.4. Respect of Rights

You have the following rights regarding your personal data, which can be exercised by writing to us at our postal address or at the following email address: anastasia.dyakonova@eurasiamarketplace.com 

 

4.4.1. Right of information, access, and communication of data

You have the possibility to access the personal data that concerns you.

Due to Eurasia Marketplace obligation of security and confidentiality in the processing of personal data, your request will only be processed if you provide proof of your identity, including a scan of your valid ID (if requested by our dedicated electronic form), or a signed photocopy of your valid ID (if written), both accompanied by the notation "I certify on my honor that this proof of identity is a certified true copy. [City], [Date]", followed by your signature.

To help you, you will find a mail template here prepared by CNIL.

 

4.4.2. Right of rectification, deletion and right to forgetting data

You have the option to request the rectification, updating, locking, or deletion of personal data that may be inaccurate, erroneous, incomplete, or obsolete.

You can also set general and specific guidelines regarding the handling of your personal data after your death. Where applicable, the heirs of a deceased person may request to consider the death of their loved one and/or to make the necessary updates.

To help you, you will find a mail template here prepared by CNIL.

 

4.4.3. Right to oppose data processing

You have the option to oppose the processing of your personal data.

To this end, you will have to write an email to anastasia.dyakonova@eurasiamarketplace.com. In this email, you will have to appoint the data you wish to be deleted as well as justifying this request, unless it is for commercial prospection reason.

 

4.4.4. Right to data portability

You have the right to receive the personal data you have provided to us in a transferable, open, and readable format.

 

4.4.5. Right to restriction of processing

You have the right to request that the processing of your personal data by Eurasia Marketplace be limited. Thus, your data can only be stored and no longer used by Eurasia Marketplace.

 

4.4.6. Withdrawal of consent

Your consent is required for the processing of your data by Eurasia Marketplace. However, you can withdraw your consent at any time. This withdrawal will lead to the deletion of your personal data.

The services requiring the processing of your data by Eurasia Marketplace will then no longer be accessible.

 

4.4.7. Response times

Eurasia Marketplace undertakes to respond to your request for access, rectification, opposition, or any other request for additional information within a reasonable period, which may not exceed 1 month from the receipt of your request.

 

4.4.8. Complaint to the competent authority

If you consider that Eurasia Marketplace 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 submit a complaint here.

 

4.5. Transfer of collected data

 

4.5.1. Transfer to partners

Eurasia Marketplace informs you that we use authorized service providers to facilitate the collection and processing of the data you have provided us. These service providers may be located outside the European Union and are provided with the collected data on the Website.

Eurasia Marketplace has previously ensured the implementation by its providers of adequate safeguards and compliance with strict conditions of confidentiality, use, and data protection.

Our Website uses social media plug-in (see the table below). When a plug-in is incorporated in a page of the Website, the social media logo appears in it. When you navigate on a page of the Website containing a plug-in, we transferred your IP address and the URL address of the visited page to the concerned social media.

The User agrees that the collected data will be transmitted by Eurasia Marketplace to its partners and will be processed by these partners as part of third-party services, namely:

 

Partner directory

  • OVH

Legal nature: Processor

Recipient country: France

Processing achieved: Cloud services

Guarantees: https://ovhcloud.com/legal/privacy-policy

  • Google Analytics

Legal nature: Processor and joint controller

Recipient country: USA (Privacy Shield)

Processing achieved: Development of business statistics to generate reports on the interactions of Users.

Guarantees: https://policies.google.com/privacy

 

  • Google Adwords

Legal nature: Processor and Joint controller

Recipient country: USA (Privacy Shield)

Processing achieved: Carrying out operations relating to prospecting.

Guarantees: https://policies.google.com/privacy

 

  • Linkedin

Legal nature: Joint Controller

Recipient country: USA (Privacy Shield)

Processing achieved: Management of people's opinions on products, services or content.

Guarantees: https://www.linkedin.com/legal/privacy-policy

 

  • Wix

Legal nature: Processor

Recipient country: USA (Privacy Shield)

Processing achieved: Website Hosting

Guarantees: https://fr.wix.com/about/privacy 

 

  • AWS

Legal nature: Processor

Recipient country: USA (Privacy Shield)

Processing achieved: Data hosting via the REDIS service

Guarantees: https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice_French_2020-08-15.pdf

 

4.5.2. Transfer on requisition on court order

The User also consents that Eurasia Marketplace may communicate the collected data to any person, at the request of a state authority or by court order.

 

4.5.3. Transfer as part of a merger or acquisition

If Eurasia Marketplace is involved in a merger, asset sale, financing transaction, liquidation, or bankruptcy or in the event of the acquisition of all or part of its business by another company, the User consents that the collected data be transferred by Eurasia Marketplace to this company and that this company carries out the processing of personal data referred to in this Privacy policy instead of Eurasia Marketplace.

 

ARTICLE 5. INTELLECTUAL PROPERTY

 

5.1.  Legal protection of the Website Contents

The Website and the Software contents may be protected by copyright and database rights. Any representation, reproduction, translation, adaptation or transformation, in whole or in part, made illegally and without the consent of Eurasia Marketplace or its successors or assignees is a violation of Books I and III of the French Code of Intellectual Property, and may give rise to prosecution for infringement.

 

5.2. Contractual protection of the Website contents

The User contractually undertakes to Eurasia Marketplace not to use, reproduce, or represent in any way the Website contents, whether or not it is protected by intellectual property rights, for a purpose other than their reading by a robot or a browser. This prohibition does not apply to web crawlers which have the sole purpose of scanning the Website content for indexing purposes.

 

ARTICLE 6.FINAL PROVISIONS

 

6.1.  Modifications

This Privacy Policy may be modified at any time by Eurasia Marketplace. The conditions applicable to the User are those in effect when they log on to the Website. Any substantial modification of the present Privacy policy will be notified to the User at its first connection following their entry into force. This new privacy policy will then be subject to a new acceptance.

 

6.2. Entirety

The invalidity of any clause of this Privacy Policy will not invalidate the remaining Privacy Policy clauses, or the Privacy Policy as a whole, which will retain its full force and scope. In such a case, the parties will, as far as possible, replace the invalid provision with a valid provision that corresponds to the spirit and purpose of this Privacy Policy.

 

6.3.  Non-Waiver

Lack of exercise by Eurasia Marketplace of rights herein acknowledged shall in no case be construed as a waiver of those rights.

 

6.4. Languages

This Privacy Policy is written in French.

 

6.5. Unfair terms

The stipulations of these terms and conditions apply subject to compliance with the mandatory provisions of the French Consumer Code on unfair terms in contracts entered between a professional and a consumer.

 

ARTICLE 7.LEGAL PROCEEDINGS

 

7.1. Applicable law

This Privacy Policy is subject to the application of French law and European regulation, including the General Data Protection Regulation.

 

7.2. Disputes

Under order No. 2015-1033 of 20 August 2015, all disputes that may arise in the context of the execution of these terms and conditions, and for which an amicable solution has not been found between the parties, must be submitted to Medicys: www.medicys.fr.

 

7.3. Arbitration

Any dispute concerning or in relation to this agreement must be settled by arbitration in accordance with the FastArbitre regulation of the Digital Institute of Arbitration and Mediation.