Updated on 19 May 2024

The company (hereinafter "the Company" or "we") refers to OserPlus Varela Consulting. 

The purpose of the General Confidentiality and Personal Data Protection Policy is to inform you about the personal data that the company collects and how it is used.

1/ General information : 

• The data controller 

The Data Controller, Ms Jocelyne Varela, acting on behalf of OserPlus Varela Consulting, is responsible for ensuring compliance with data protection regulations.

The Company is responsible for processing the data of its customers and more generally of Internet users (hereinafter referred to as "you") browsing the websites that it operates as part of its activities, and their sub-sites, including the online training platform and/or private group on a social network offered to its customers (hereinafter referred to interchangeably as the "Site").

2/ Definitions : 

For a proper understanding of this Privacy Policy, the following terms should be specified: 

- Personal data" means any information relating to an identified or identifiable natural person (the "data subject"); an "identifiable natural person" is one who can be identified directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her identity.

- Purpose of processing personal data: the purpose of processing personal data is the objective pursued by said processing. For example, it may be used to manage the order and registration process or to provide the online training area. 

- Data controller: the natural or legal person who determines how personal data is processed and under whose responsibility the processing is carried out.

- Sub-processor: natural or legal person who processes personal data on behalf of a controller. 

- Processing" means any operation involving personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Warning. Please be careful about what you make public on the Internet. With regard to personal data, including data relating to your private life or sensitive data (political and philosophical opinions, trade union membership, information about your health, sexual orientation, religious beliefs, etc.) made public at your initiative or deduced from your contributions, comments and opinions of any kind on social networks (Facebook, Youtube, etc.), please note that the processing of personal data made public by the person concerned is not subject to the prohibition in principle on the processing of sensitive data.

If a word is capitalized, the Customer may refer to the general terms and conditions of sale applicable on the Site.

3/ Legal basis for the processing operations :  

Depending on your situation, your registration status or the service subscribed to, the processing of your personal data by the Company may have a legal basis:

• a legal obligation ;
• the legitimate interest of the establishment or a third party ;
• consent, where no other legal basis exists or for the processing of "sensitive data".

4/ Personal data collected and processed: 

The provision of a virtual space for access to services: 

The content of the training is delivered on a dematerialised or materialised platform accessible via a URL link provided to the Customer at the time of ordering. Coaching is delivered via private groupings on the Circle platform.

All account holders who access a virtual space (training, viewing, coaching group, etc.) have access rights that are strictly personal, confidential and non-transferable. All account holders must take the necessary security measures to preserve the integrity of their access rights (login, password) to prevent third parties from connecting to their account. The holder of access rights shall be liable for any fraudulent or abusive use of his/her access codes, where this results from his/her own negligence. In any event, the holder of access rights must inform us without delay of the loss or theft of his/her identifiers.

Email Notifications - The "Please notify me of updates to my products" and "Please notify me when a reply to one of my messages or comments is created" boxes that may be provided to Customers on a virtual space to receive email notifications (product updates, replies to one of my messages or comments) may be unchecked at any time.

• Monitoring our relationship:
• Payment management : 
• Marketing and advertising targeting activities

5/ Recipients of your personal data : 

We do not sell any personal data files. The information you give us is for internal use by authorised persons. It is strictly confidential and may not be disclosed to third parties, except with your express consent or if you have decided to make it public.

As part of the processing described above, our external service providers may receive personal data in order to carry out the processing. This is the case for tools supplied under the names Clickfunnels (orders), Goddady (website hosting), Kajibi (training platform, access management including password), FreshDesk (customer support).

To this end, we check that any processor provides sufficient and appropriate contractual guarantees to respect your rights, so that the processing meets the requirements of the GDPR and complies with the GDPR provisions applicable to data transfers.

On the basis of our legal obligations, your personal data may be disclosed in application of a law, a regulation or by virtue of a decision by acompetent regulatory or judicial authority.

Transfers outside the EU. We undertake to comply with the applicable regulations relating to the transfer of data to countries outside the European Union, in particular in accordance with the following procedures:

- We will transfer the data of visitors, prospects and customers to countries recognised as offering an adequate level of protection. In the case of transfers to the United States, to organisations that have signed up to the Privacy Shield;

- When the country of destination does not have an adequate level of protection, we use transfer tools that comply with the regulations (in particular the European Commission's standard contractual clause).

6/ Data protection : ‍

We undertake to implement all appropriate technical and organisational measures using physical and logistical security measures to guarantee a level of security appropriate to the risks of accidental, unauthorised or illegal access, disclosure, alteration, loss or destruction of your personal data.

• Secure payment

All transactions carried out on our Site are secure. Credit card payments are handled by our partner STRIPE, which is a trusted payment service provider. We use an SSL encryption system to protect your personal data and the means of payment used. At no time do we have direct access to your bank details through this process.

The address of the payment page begins with "https" and is accompanied by a closed padlock or a key in the bottom right-hand corner of your browser. This allows you to check that you are in a secure payment zone when you are asked for your bank card number. Stripe automatically checks that this connection is secure before sending your banking and transaction data.

• Data breach

In the event that we become aware of unlawful access to your personal data stored on our servers or those of our service providers, or of unauthorised access resulting in the risks identified above, we undertake to :

- Notify you of the incident as soon as possible if this is required by law;

- Examine the causes of the incident;

- Take all necessary measures within reasonable limits to mitigate the negative effects and damage that may result from the said incident

Under no circumstances may the undertakings defined in the above point be assimilated to any recognition of fault or responsibility for the occurrence of the incident in question.

If you observe any security breach or any incident likely to affect the integrity of your personal data or that of others, we would be grateful if you would inform us immediately by e-mail at jocelyne@oserplus.com.

7/ Use of cookies :  

• Types of cookies used

We attach particular importance to your knowledge of The Company's use of cookies. Depending on its websites, the company uses cookies:

• necessary for the proper operation of the site;
• audience measurement and statistics.

These cookies are kept for a maximum of 13 months.

• Cookies required for the site to function properly

These cookies have the following functions in particular:

• session cookies. They are used to keep the session active when identification is required;
• cookies used to store preferences and personalise services;
• cookies intended to ensure the security of the services provided.

As these cookies are necessary for the proper operation of the websites on which they are placed, they are not conditional on or subject to your consent. Failure to use them could lead to serious malfunctions on the sites.

• Cookies used to measure audience and traffic

The company uses this type of cookie to obtain feedback on the number of visits to its sites and the way in which they are used. The information gathered in this way enables the company to continually improve its services and make them compatible with the equipment used, in order to best meet the needs of its visitors.

• Marketing cookies

These cookies store a certain amount of information, such as the pages you have visited on the sites, in order to provide you with personalised offers.

These cookies are only deposited with your consent.

• Opposing the use of a cookie

You can accept or refuse the cookies used by the company's websites. To do this you can :

• set the parameters for the cookies you accept or reject directly via the console on the site;
• set your browser parameters. If you do not want cookies to be used on your terminal, most browsers allow you to deactivate cookies via the settings options:

- For Chrome : https://support.google.com/chrome/answer/95647?co=GENIE.PlatformAndroid& hl=fr

- For Safari :
https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

However, you should be aware that if you deactivate the use of cookies, the quality of your browsing on the websites may be impaired. Some services may also malfunction. The Cned cannot be held responsible for this.

8/ Exercising your rights:

• Your rights 

In accordance with applicable data protection regulations, you have the following rights in relation to your personal data:

• right of access to your data: you can request a copy, in plain language, of all the data we hold on you
• the right to erasure of your data: you may ask for all your personal data to be erased unless it is still necessary for the performance of certain operations, compliance with a legal obligation or the establishment, exercise or defence of legal claims.
• right to rectify your data: you can ask for inaccurate or incomplete information about you to be corrected
• the right to withdraw your consent: you may withdraw your consent at any time, by means of a simple procedure equivalent to that used to obtain your consent
• right to object to processing: you have the right to object to any use of your personal data. You may ask to exercise your right to object to the processing of your personal data on grounds relating to your particular situation where the processing is based on our legitimate interests.
  If you exercise your right to object, we will cease processing. Your request may be refused if there are compelling legitimate grounds which override your interests, rights and freedoms or if your data is necessary for the establishment, exercise or defence of legal claims.
• right to data portability: you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to pass it on to another organisation
• the right to restrict processing: you may ask for a temporary freeze on the use of some of your data in order to verify its accuracy, to oppose its deletion or to exercise or defend your legal rights

9/ How to exercise your rights:  

For a request to exercise your rights or for any other question, general or specific, relating to data protection
If you do not wish to receive your personal data, you can contact us and we will give you a reply within 1 month of receiving your request.

- E-mail address: jocelyne@oserplus.com

If you are not satisfied with our response, you may lodge a complaint with the authority responsible for monitoring and protecting personal data (for example, in France, the CNIL).

10/ Retention of your personal data: 

• Data retention period

Each item of data is stored for a limited period corresponding to the time required to carry out the treatment. This period therefore varies according to the treatment.

• Destruction, anonymisation and archiving of data

At the end of the retention period required for the purpose concerned, personal data is :

• or permanently deleted;
• or anonymised and kept in this form;
• Anonymisation is an irreversible process. It is therefore no longer personal data;
• archived if the Company is obliged to do so by law or if this is justified by the Company's legitimate interests (e.g. statute of limitations).

During this archiving period, the data is kept but is no longer accessible or used by the Company. At the end of the archiving period, the data is permanently deleted. 

For further information, please consult our legal notice and general terms and conditions of sale.