Privacy
Editions Comte (info@editionscomte.com)
1. NAME AND ADDRESS OF THE CONTROLLER
The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States as well as other data protection laws is:
Editions Comte
Andreas Putsch
9 Rue du Faubourg Saint-Honoré
75008 Paris
E-Mail: info@editionscomte.com
2. DELIVERY OF THE WEBSITE \ RECORDING OF LOG FILES
Description of data processing
When our website is visited by the program used by the visitor to display internet pages (the so-called web browser or just browser), which the visitor has installed on his end device, the following information is transferred to the web server we use:
• date and time of the call of our web pages
• the time difference between the requesting host and the web server
• the content of the request or the file that was transferred to the visitor
• the access status (successful transmission, error, etc.)
• the amount of data transferred in each case in bytes
• the website from which the visitor’s access was made
• the browser used by the visitor, the operating system, the interface, the language of the browser and the version of the browser software.
Furthermore, we collect the so-called IP address of the visitor when visiting our website via the browser. All computers and devices connected to the internet are assigned an IP address (Internet Protocol), usually in country-specific blocks. Often, this can be used to determine the country, the state, and the location where the Internet connection is established. IP addresses must be used so that websites can be visited on the internet. Thus, owners of websites like us have access to the IP addresses of the visitors to their website.
This information is stored by us on our web server in a so-called log file. This would at least indirectly enable us to establish a link to a person, i.e. by determining the owner of the IP address via information from the provider of the IP address.
Purpose of data processing
The temporary storage of the IP address through the system is necessary to enable the delivery of the website to the visitor’s computer. For this purpose, the IP address of the visitor must remain stored for the duration of the session.
The above-mentioned log les are processed by us to ensure a smooth connection to our website, to track and solve technical problems, to correct errors in our website, to prevent any attacks on our website and to ensure a comfortable use of our website.
We do not use this data for automated individual decision-making or profiling within the meaning of the GDPR.
The legal basis of the processing is Art. 6(1)(f) GDPR (legitimate interest of the controller). Our legitimate interest follows from the purposes of data processing set out above.
Period of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the delivery of the website, this is the case when the respective session has ended. In the case of storage of data in log files, this is the case after seven days at the latest.
No requirement to provide personal data
You are neither legally nor contractually required to provide us with the above-mentioned data, nor is their disclosure necessary for the conclusion of a contract. If you do not wish the above-mentioned data to be processed, you can no longer visit the website.
3. CONTACT INFORMATION
Description of future data processing
When you download images of our art collection, you have the option to provide your contact information on a voluntary basis. In this case, we collect and process the following data of the visitor (contact information):
• First and last name
• Home address
• Telephone number
• E-mail address
For the processing of the above-mentioned data, your consent is obtained during the registration process. In the near future, this will be implemented by using the so-called double opt-in procedure, according to which you will also receive a confirmation e-mail with a link to reconfirm your consent after having given your consent using the input form on the website.
Purpose of data processing
We use the contact information to inform you periodically by e-mail about
the Editions Comte including its idea, works of art, and artists. We may also use the above-mentioned data to inform you by e-mail about exhibitions of works of art included in the art collection and to invite you to such exhibitions and related events.
We do not use this data for automated individual decision-making or profiling within the meaning of the GDPR.
Legal basis of processing
The legal basis of the processing is Art. 6(1)(a) GDPR (consent of the data subject).
You have the right to withdraw your consent at any time without affecting the lawfulness of the processing carried out based on the consent before its withdrawal.
You can use the following unsubscribe link to withdraw your consent: URL. This link is included at the end of every automated e-mail sent by the controller. Alternatively, you can withdraw your consent by sending an e-mail to info@editionscomte.com.
In the event of a withdrawal of consent, we will no longer process the contact information for the above-mentioned purposes.
Period of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. Accordingly, the contact information will be stored until you have withdrawn your consent.
No requirement to provide personal data
You are neither legally nor contractually required to provide us with the contact information, nor is its disclosure necessary for the conclusion of a contract. If you do not wish your contact information to be processed, you may download images of works from the art collection without providing your contact information. In this case, you will not receive information about the art collection by e-mail, nor will you be notified of exhibitions or invited to such exhibitions and related events by e-mail.
4. RECIPIENTS OF PERSONAL DATA
Our website is operated on our behalf by Bergos AG, Kreuzstrasse 5, CH-8008 Zurich, Switzerland. Bergos AG, in turn, uses the following hosting provider to host the website:
cyon GmbH
Brunngässlein 12
CH – 4052 Basel
Switzerland
We have concluded a data processing agreement with Bergos AG. According to this agreement, Bergos AG is required to process the data only on our behalf and in accordance with our instructions. Bergos AG, in turn, has concluded a corresponding data processing agreement with the hosting provider. Further information on the data processing by the hosting provider can be found in its privacy policy at https://www.cyon.ch/legal/datenschutzerklaerung.
Personal data will not be disclosed to persons other than Bergos AG and cyon.com.
5. PLACE OF DATA PROCESSING
Personal data is processed in the European Union and in Switzerland.
According to the decision of the European Commission, Switzerland has an adequate level of data protection within the meaning of Article 45(1) GDPR in conjunction with Article 45(6) GDPR. You can view the adequacy decision of the European Commission at the following link: h=ps://eur-
lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32000D0518
A transfer of personal data to other countries outside the European Union (third countries) does not occur.
6. YOUR RIGHTS
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:
Right of access
You have right to obtain from us a confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, you have the right to access to the personal data and to the following information:
• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, • the criteria used to determine that period;
• the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
• the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling, according to Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
You have the right to request information about whether personal data concerning you is transferred to a third country or to an international organization. You have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to any transfer.
Right to rectification
You have the right to obtain from us without undue delay the rectification of inaccurate personal data that concerns you.
Right to restriction of processing
You have the right to obtain from us restriction of processing where one of the following applies:
• you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• we do no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise, or defense of legal claims;
• you have objected to processing pursuant to Article 21(1) GDPR pending the verification whether our legitimate grounds override those of you.
Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
Right to erasure
You have the right to obtain from us the erasure of personal data concerning you without undue delay and we are required to erase personal data without undue delay where one of the following grounds applies:
• the personal data are no longer necessary in relation to the purposes for which we collected or otherwise processed them;
• you withdraw your consent on which the processing is based according to Article 6(1)(a) GDPR, and where there is no other legal basis for the processing;
• you object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation in European Union or Member State law to which the controller is subject.
The right to erasure does not apply to the extent that processing is necessary:
• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation which requires processing by European Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of social authority vested in the controller;
• for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) GDPR as well as Article 9(3) GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) GDPR in so far as the right to erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing; or for the establishment, exercise, or defense of legal claims.
Right to data portability
You have right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where:
• the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR; and
• the processing is carried out by automated means.
In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.
Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you that we process on the legal basis of legitimate interest (Article 6(1)(a) GDPR), including profiling based on this provision. In such case, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
You have the right to object at any time to the processing of personal data for the purpose of direct marketing, including profiling in connection with direct marketing. In this case, we will no longer process the personal data concerning you for the purpose of direct marketing.
Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data infringes the GDPR. A list of supervisory authorities can be found at the following link: h=ps://edpb.europa.eu/about-edpb/about-edpb/members_en.