PRIVACY POLICY

Preamble

This privacy policy is intended for all users of our services and aims to inform you about how your personal information may be collected and processed. Respecting privacy and personal data is a priority for us, which is why we commit to handling this data in strict compliance with Law No. 78-17 of January 6, 1978, relating to data processing, files, and freedoms, as amended (hereinafter “IEL law”), and Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter “GDPR”).

In any case, we commit ourselves to respecting the following three (3) essential principles:

• Your data will not be subject to any commercial exploitation;

• You remain in control of your personal data;

• Your data is processed in a transparent, confidential, and secure manner;
  
  

Article 1. Definition 

The terms mentioned below have the following meaning in this Privacy Policy:

• “Personal Data” or “Personal Information“: refers to personal data within the meaning of the French Data Protection Act and the GDPR, and more generally, any information related to an identified or identifiable natural person;

• “Site“: refers to the online platform accessible from the website www.sourcegroup.marketing.

 et permettant de bénéficier des Services. La Plateforme regroupe l’ensemble des pages web et fonctionnalités proposées aux Utilisateurs.

• « Services » : désigne l’ensemble des services proposés par www.sourcegroup.marketing aux Utilisateurs par l’intermédiaire de la Plateforme ;

• « Utilisateur » : désigne toute personne qui accède et navigue sur le site web.
  
  

Article 2. Identity of the data controller

The data controller is Innovacore Group LLC (Source Agency) in its capacity as the publisher of the website. www.sourcegroup.marketing. 

Under the current regulations related to the protection of personal data, www.sourcegroup.marketing is obligated to protect such data.

Legal Reminder:
The data controller is, within the meaning of the Data Protection Act and the GDPR, the person who determines the means and purposes of the processing. When two or more data controllers jointly determine the purposes and means of processing, they are joint controllers of the processing (or co-controllers).

The subcontractor is a person who processes personal data on behalf of the data controller, acting under the authority and instruction of the data controller.

With that said, this privacy policy pertains to the processing of personal data carried out by www.sourcegroup.marketing in the context of operating the Site in its capacity as the data controller.

Article 3. Purposes and Categories of Personal Data Collected

www.sourcegroup.marketing

Collects and processes personal data. Please find below the list of elements we collect categorized by type and their associated purposes. Contact Information: name, first name, email address, landline or mobile phone number, profession, postal address. This type of data is used to:

• contact you to assess your needs
• prepare quotes
• carry out loyalty operations
• manage people’s reviews about the agency

Legal basis for processing:

Consent (Article 6.a GDPR): The user has freely consented to the processing of their personal data.
Connection and browsing data: connection and usage data, IP address. This type of data is used for:

• Improving the system’s development by enabling better navigation on the site.
• Creating statistics.
• Preventing fraud risks and ensuring user authenticity.
• Legal bases for processing:

Consent (Article 6.a GDPR): The user has consented to the processing of their personal data (see Article 11. Cookies).
Legitimate interest (Article 6.f GDPR) in providing users with the best possible experience on the site and the highest quality of services offered.
 

Article 4. Recipients of your data

www.sourcegroup.marketing is currently the sole recipient of your personal data. Furthermore, none of your personal information is published without your knowledge, exchanged, transferred, assigned, or sold in any way to third parties.

In cases where the law requires it, certain authorized third parties (relevant authorities, mediators, lawyers, bailiffs, and other legal professionals) may have access to your personal data.

Article 5. Transfer of data outside the European Union

By principle, the agency commits to not carry out any operation of transfer of Users’ personal data outside of the European Union. However, in the event that a transfer arises, the agency undertakes to comply with the regulations applicable to the transfer of data to a country located outside the European Union. All necessary precautions will be taken to regulate the transfer.

Article 6. Duration of Data Retention

Personal data is processed and retained by the Agency from the moment you get in touch. These data will not be kept for a period exceeding the time necessary for the accomplishment of the purposes pursued by the agency in the operation of the Site (cf. Article 3).
In the event of a virtual or physical appointment proposal that is not followed, or electronic exchanges that do not receive a response, all personal data related to the collected file will be deleted within a maximum period of 25 weeks.

In any case, the retention period for your personal data does not exceed a period of 36 months (3 years) from the last login or activity on our site. After this period, they will be deleted.

In all other cases, the data will be retained for a maximum period of 5 years from the last contact made by the Agency, unless there is a specific requirement. After this period, they may be anonymized or archived for statistical and evidentiary purposes.

Article 7. Your Rights

In accordance with the French Data Protection Act and the GDPR, you have the following rights concerning the processing of your personal data:

• The right of access (Article 15 GDPR) to and the right to rectify (Article 16 GDPR) your data, to update, and to complete your data.
• The right to erasure (or “right to be forgotten”) of your personal data (Article 17 GDPR) when they are inaccurate, incomplete, ambiguous, outdated, or when their collection, use, communication, or preservation is prohibited.
• The right to withdraw your consent at any time if a processing is based on this legal basis (Article 7 GDPR).
• The right to restrict the processing of your data (Article 18 GDPR).
• The right to object to the processing of your data (Article 21 GDPR).
• The right to data portability of the data you have provided, when your data is subject to automated processing based on your consent or on a contract (Article 20 GDPR).
• The right to define the fate of your data after your death and to choose whether or not to communicate your data to a third party you have previously designated. In the event of death and in the absence of instructions from you, we commit to destroying your data, unless its retention is necessary for evidential purposes or to fulfill a legal obligation.

You can exercise your rights:

• By mail at this postal address: 1200 Brickell Avenue, Suite 1950 #1082, 33131 Miami, Florida, United States.
• By email at this address: hello@sourcegroup.marketing

Finally, you can also lodge a complaint with the supervisory authorities, especially the CNIL (https://www.cnil.fr/fr/plaintes) or any other competent authority.

Article 8. Cookies

Our website, www.sourcegroup.marketing, uses cookies. A cookie is a small text file issued by a website’s server and stored on the hard drive of your computer or mobile device. The cookie contains a unique code that recognizes your browser during your visit to our website or during future repeated visits.

Cookies generally ensure easier and faster interaction between the visitor and the website (for example, a cookie remembers viewing specific content and does not offer it again). They remember your preferences, thus speeding up your subsequent access to the site and facilitating your visits. A cookie typically contains the name of the server that placed the cookie, an expiration date, and a unique encrypted code.

The duration of cookie storage is limited to 13 months after their first deposit in the user’s terminal, as is the validity period of the user’s consent to their use. Under no circumstances is their storage duration extended with each visit. Therefore, the user’s consent must be renewed after this period.

Our site www.sourcegroup.marketing uses several types of cookies:

• Cookies strictly necessary for navigation: these cookies are required for visiting our website and using it securely and optimally. They allow you to navigate between the different sections of the site.
• Hubspot cookies (tracking cookies): these cookies are used to track visitors to our Site when they use it and also to identify them on a subsequent visit.
• Google Analytics cookies: these cookies are intended to collect information about users to enable us to have an in-depth and real-time view of how our site is used. They allow us to generate statistics.

The information collected by cookies is anonymous and does not allow your identification as a person. Indeed, the information related to cookies cannot be associated with a name and/or first name because it does not contain personal data.

It is possible to oppose the use of cookies:

• Either from our cookie banner where you can set your preferences for the use of cookies.
• Or from your browser settings. The configuration of each browser is different. It is up to you to follow the instructions of your browser’s publisher.
• If you use Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
• If you use Safari: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
• If you use Firefox: https://support.mozilla.org/fr/kb/cookies-informations-sites-enregistrent#w_paramaetres-des-cookies
• If you use Chrome: https://support.google.com/chrome/answer/95647

We warn that in the case of refusal to record cookies, the browsing experience on our site may be limited. We therefore decline any responsibility for the consequences related to the degraded operation of the site, resulting from the refusal of cookies on your part. For any request regarding cookies, you can contact the agency at hello@sourcegroup.marketing.

Article 9. Minors

The website and Services are not intended for minors. In any case, www.sourcegroup.marketing does not knowingly collect personal data from minors under the age of 15.

If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us by email at hello@sourcegroup.marketing or by postal mail at the following address: 39 rue Georges Courteline, 60100 Villeurbanne, providing your first and last names, email and postal address.

Article 10. Security

www.sourcegroup.marketing respects the GDPR and the Data Protection Act in terms of data security and privacy. Therefore, through physical and logical security measures (firewalls, SSL encryption, strong passwords), the agency implements all useful and necessary technical and organizational measures to ensure the security of personal data processing and the confidentiality of the collected data.

To this end, all necessary precautions are taken, considering the nature of the data and the risks presented by the processing, to preserve its security. This includes preventing the data from being distorted, lost, damaged, disclosed unauthorizedly, or accessed by unauthorized third parties.

Article 11. Contact 

All questions, comments, and requests concerning this privacy policy or any other inquiries are welcome. They should be addressed either by postal mail or email.

Postal Address: 1200 Brickell Avenue, Suite 1950 #1082, 33131 Miami, Florida, United States
Email Address: hello@sourcegroup.marketing

Article 12. Revision and updating of the privacy policy 

We are always committed to processing personal data in accordance with the current legal provisions. This policy will be reviewed in light of legislative and regulatory developments. In any case, you will be regularly informed of this update. (Updated on: 07/18/2023)